Republic of the Philippines

MUNICIPAL TRIAL COURT

Branch I
Surigao City

____________________________,
Plaintiff,
CIVIL CASE NO. 2016-003
-versus- FOR COLLECTION OF SUM
OF MONEY with DAMAGES
____________________________
Defendant.

/------------------------------------------------/

ANSWER
COMES NOW, the defendant, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:
1. That he ADMITS the contents of paragraph 2 only insofar as his personal
circumstances are concerned;
2. That he ADMITS his obligation in the principal amount of TWO HUNDRED
FIFTY THOUSAND PESOS ( 250,000), Philippine Currency as cited in
paragraph 3 of the complaint.
3. That defendant does not, at the moment, have all the records of payments he made
to plaintiff, so that he also does not have information sufficient to form a belief as
the truth of the allegations in paragraph 4 regarding the Outstanding Balance
amounting to ONE HUNDRED TWENTY FIVE THOUSAND PESOS
(125,000) Philippine Currency of the complaint and, therefore, DENY them.
4. That defendant is without knowledge or information sufficient to form a belief as to
the veracity of the averments in paragraph 5 of the complaint;

WHEREFORE, the defendant respectfully prays that the complaint be

dismissed with costs against the plaintiff.

Other relief and remedies as may be deemed just and equitable under the
premises are likewise prayed for.

City of Surigao, March 15, 2016.

 __________ LAW OFFICE
Counsel for the Defendant
1982 P-7 Brgy. San Juan
Surigao City, SDN

By:

ATTY. __________________________
Roll No. 98756
IBP No, 12345/1-3-2012/Surigao
PTR No. 34567/1-3-2012/Surigao

Copy furnished:

ATTY. _______________
Counsel for the Plaintiff
Roxas cor. Narciso St.
Surigao City, SDN

EXPLANATION

Copy of the foregoing ANSWER was served to plaintiffs counsel by registered

mail due to time and distance constraints and for lack of the undersigneds staff who
can serve the same in person.

ATTY. ______________