LEYTECIA A. ESPIÑA
Plaintiff,
EUSEBIA A. DE ASAS,
Defendant.
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ANSWER
I. Answer
4. The title and ownership in fee simple over the subject property is within the
name of Macrina M. Espiňa and not the plaintiff.
5. The plaintiff is not “the owner” in fee simple of the subject property, contrary to
her allegation in Paragraph 3 of the Complaint.
9. By reason of the abuse of rights committed by the plaintiff and by the reason of
the instant precipitate and unfounded suit, the defendant was constrained to
hire the services of a lawyer to defend his rights and interest s for a professional
fee of P20,000 plus P3,000 pesos per Court Appearance;
10. Similarly, the plaintiff’s unfounded suit has caused the defendant mental
anguish and suffering and public humiliation and embarrassment, for which the
defendant claims moral damages of P50,000.
IV. Prayer
The Defendant respectfully prays for such and other reliefs as may be deemed just
and equitable.
1. I am the defendant in the foregoing case; that I caused the preparation of the
foregoing Answer; that I have read its contents; and that the same are true and
correct of my own direct, personal knowledge.
2. Further, pursuant to Rule 7 of the 1997 Rules of Civil Procedure and existing
Supreme Court circulars, I hereby certify that I have not heretofore commenced
any other action or proceeding involving the same issues in 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; and that if I should hereafter
learn that other similar or related actions or proceedings has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other tribunal or
agency, I undertake to report that fact within five (5) days therefrom to this court.
EUSEBIA A. DE ASAS
Affiant
OSCA I.D. No. 1397 issued on 30 June 2008
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Serie of 2019