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Republic of the Philippines

Regional Trial Court


7th Judicial Branch
Branch No.____
Cebu City

MILO, Plaintiff
CIVIL CASE No. _____
-versus- For: Collection of Sum of
Money

JIFEL, Defendant
x-----------------------------------------------x

ANSWER

COMES NOW the Defendant, through the undersigned counsel, and


unto this Honorable Court, respectfully manifest that;

1. Defendant ADMITS Paragraphs one (1) to five (5) of the Complaint.

2. Defendant specifically DENIES the allegations contained in


Paragraph six (6) as well as the attachment thereof, the truth of the
matter being those alleged in the Affirmative Defenses herein stated
below.

3. Paragraph seven (7) is DENIED insofar as it alleges that Plaintiff


made written demands, the truth of which is contained in the
Affirmative Defenses herein below.

4. Paragraph eight (8) is likewise DENIED for lack of knowledge or


information sufficient to form a reasonable belief as to its veracity or
falsity, the allegations therein being matters only known to the
plaintiff.

Affirmative Defenses

Defendant reiterates by reference all the foregoing insofar as they are


material and additionally submit that the Complaint should be dismissed
because:

5. No written demand from Plaintiff came into the knowledge of


Defendant;
6. The attached letter in Annex “B” neither shows any indication that
such letter was received by the Defendant or his legal representative;

7. Even if there was indeed a demand letter, Plaintiff no longer has a


cause of action for the collection of sum of money, such action having
been already prescribed after 10 years of maturity of the debt.

WHEREFORE, the above premises considered, Defendant


respectfully prays of this Honorable Court that the Complaint be
DISMISSED on the ground of prescription.

Other relief just and equitable in the premises are likewise prayed for.

Cebu City, Philippines, this 23rd day of February, 2017.

ATTY. MAUREEN N. CAÑETE


Counsel for Petitioner
MC Law Firm, UC Banilad, Cebu City
Roll of Attorneys No. 0518995
IBP No. 0518995 Lifetime/Cebu City
MCLE No. 1234567
PTR No. 98765432