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Republic of the Philippines Regional Trial Court Legazpi City ARTEMIO REYES, Plaintiff, ______ -versusPILAR SANTOS, Defendant

X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X ANSWER DEFENDANT, through undersigned counsel, and in answer to plaintiffs complaint, respectfully aver: 1. She admits paragraph 3 of the complaint; 2. She is without knowledge or information to form a belief as to the truth of the averments made in paragraphs 4, 5 and 6 and therefore; 3. She DENY specifically each and every material allegation made in paragra ph 4,5 and 6 of the complaint; and allege that the contract of lease between her and the plaintiff had long been terminated since 2002. Upon knowing that certai n PABLO AGUINALDO had a certificate of title over the subject land, the defendan t and Pablo Aguinaldo immediately executed a DEED OF ABSOLUTE SALE for 50,000php over such parcel of land as shown in Annex 1. 4. As AFFIRMATIVE DEFENSES, the defendant reiterates, repleads and incorpor ates by reference all the foregoing insofar as they are material and additional ly submit that the complaint should be dismiss because: 4.1 the plaintiff has no cause of action because he is not the lawful owner of the subject land: 4.2 the plaintiff is not entitled to the possession of the land as the same has already been sold to the defendant as shown by the DEED OF ABSOLUTE SALE. (A nnex 1) 5. The defendant reiterates, repleads and incorporates by reference all the foregoing insofar as they are material and additionally submit that he is enti ted to reiefs arising from the filing of this malicious and baseless suit as fol lows: 5.1 Moral Damages amounting to Thirty Thousand Pesos(Php 30,000) because her name and reputation were besmirched by this malicious and baseless suit. 5.2 Attorneys fees amounting to Fifteen Thousand Pesos(Php 15,000) because he was compelled to secure the services of a counsel to vindicate his legal rights . PRAYER WHEREFORE, the defendant respectfully prays that the ju dgment be rendered in his favor by dismissing the Complaint and granting the def endants counterclaim by awarding the defendant (a) Thirty Thousand as Moral Dama ges and (b) Fifteen Thousand as Attorneys Fees.

CIVIL CASE No. For: ___________

Other just and equitable reliefs are likewise prayed for. Legazpi City, Philippines, July 25, 2011. Atty. Clarissa Juanita de la Cruz Counsel for Defendant Lapu-lapu St. Legazpi city Tel. No. (052)4809912 Roll of Attorney No. ______ IBP No. ______ PTR No. ______ MCLE Compliance No._____

VERIFICATION I, PILAR SANTOS, Filipino, married, of legal age, and wi th residence at Caguiba, Camalig Albay, respectively after having been sworn in accordance with law, depose and state that: 1. I am the defendant in the above-entitled case; 2. I have read and understood the allegations therein and the same are true and correct of our own personal knowledge and/or based on authentic records; IN WITNESS WHEREOF, I have signed my name this 25th of J uly, 2011 in Legazpi City, Philippines. PILAR SANTOS Affiant JURAT EXPLANATION A copy of the ANSWER is served by registered mail instea d of by personal delivery due to unavailability of personnel to effect personal delivery. Atty. Clarissa Juanita de la Cruz Copy Furnished: Atty. Simon Macaraig Counsel for the Plaintiff Alatco Subd., Daraga, Albay