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Republic of the Philippines

METROPOLITAN TRIAL COURT


National Capital Judicial Region
Branch ____, Quezon City

Defendant.

NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS

CIVIL CASE NO. _____


For: Collection of a
Money

Sum

of

X - - - - - - - - - - - - - - - - - - - - - - - - - - -X

ANSWER

COMES NOW the defendant EDGARDO S. SANTOS thru the undersigned counsel,
respectfully alleges:

1. That he specifically denies under oath the genuineness and due execution of the
alleged Acknowledgement of Debt (Annex A) and Loan Agreement (Annex B) attached to the
plaintiffs complaint;

2. That the said two documents were fraudulently executed by the plaintiff
NAPOLEON C. GATMAITAN, the defendant EDGARDO S. SANTOS not having executed
any such promissory note in favor of the former, thus, the said promissory note is null and
void.

WHEREFORE, it is respectfully prayed that the plaintiffs complaint be dismissed with


costs against the plaintiff. The defendant further prays for such other relief as the Honorable
Court may deem just and equitable.

Quezon City,_____________

ATTY. LOUISE MARIE S. PEREZ


Counsel for Defendant
Citibank Tower Eastwood City Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City

VERIFICATION

I, EDGARDO S. SANTOS, of legal age, Filipino and with address at # 15 Bohol St.,
Barangay Horseshoe, Quezon City, having been duly sworn to in accordance with law hereby
depose and say:

1. That I am the Defendant in the above-entitled case; that I have caused the preparation
of the foregoing Answer Pleading; that all the allegations stated therein are true and correct of
my own knowledge and supported by authentic documents;
2. That I have not commenced any other action or proceeding involving the same issues
is the Supreme Court, the Court of Appeals, or any other tribunal or agency; that to the best of
my knowledge, no such action or proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency; that there is no other action or proceeding which is
either pending or may have been terminated, and if I should thereafter learn that a similar
action or proceeding has been filed or is pending before the Supreme Court, the Court of
Appeals, or any tribunal or agency, I undertake to report that fact within five (5) days there
from to this Honorable Court.

EDGARDO S. SANTOS
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of _______ at Quezon City
affiant exhibiting to me her Community Tax Certificate No. __________ issued in ___________
on ____________

NOTARY PUBLIC

Doc. No.________;
Page No.________;
Book No.________;
Series of ________;