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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

JIFEL, Defendant


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

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

Affirmative Defenses

Defendant reiterates by reference all the foregoing insofar as they are

material and additionally submit that the Complaint should be dismissed

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

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.


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