ANSWER
3. That although PLAINTIFF is the full-blood sister of RESPONDENT and one of the
sole heirs of DECEDENT, she has already relinquished her legal interest over
DECEDENT’s estate;
5. That before PLAINTIFF boarded the plane, she handed RESPONDENT a duly
notarized Special Power of Attorney (SPA) (attached herewith as Annex 1);
6. That the said SPA appointed RESPONDENT as the PLAINTIFF’s agent to execute
an EXTRAJUDICIAL SETTLEMENT and a DEED OF ABSOLUTE SALE in favor of the
RESPONDENT;
7. That through the SPA, PLAINTIFF (as represented by RESPONDENT as her agent)
executed an EXTRAJUDICIAL SETTLEMENT and a DEED OF ABSOLUTE SALE in favor
of RESPONDENT in the amount of TWO MILLION PESOS (Php2,000,000.00) on
February 28, 1982 (attached herewith as Annex 2 and Annex 3, respectively);
9. By reason of the unfounded suit, RESPONDENT had no choice but to hire the
services of a lawyer to defend her rights and interests for a professional fee of
FORTY THOUSAND PESOS (Php 40,000) plus TWO THOUSAND (Php 2,000.00) per
appearance;
PRAYER
Plaintiffs pray for such other reliefs and remedies that are just and equitable
under the premises.
Cebu City, Philippines. Month Day, Year.