REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL REGION REGIONAL TRIAL COURT, BRANCH 12 QUEZON CITY

MICHAEL ROMERO, PLAINTIFF Civil Case No: 5501

Versus

MARIO DINGLASAN, DEFENDANT

X------------------------------------------------------------------------------------------------X ANSWER

COMES NOW, the Defendant, through the undersigned counsel and unto this Honorable Court, most respectfully avers: 1. That Defendant ADMITS all the allegations enumerated under the Common Causes of Action stated in Paragraph 1, 2 and 3; 2. That Defendant ADMITS the portion of paragraph 4 which states that he actually received subject office equipment with the value of Eight Million Pesos (Php 8,000,000.00); ANSWER FOR THE FIRST CAUSE OF ACTION 3. That Defendant ADMITS in paragraph 5 remitting the amount of Three Million Pesos (Php 3,000,000.00) but DENIES under oath that having sold the office equipment worth Four Million Pesos (Php 4,000,000.00); 4. That Defendant ADMITS alleged encounter of demands as stated in paragraph 6 and 7; ANSWER FOR THE SECOND CAUSE OF ACTION

5. That Defendant DENIES failure to disclose the names of buyers of credit, as alleged in paragraphs 9 and 10, as such can be found in the Record of Inventory. Thus, herein Defendant is not obliged to pay and secure payment for the office equipment as alleged in paragraph 11 of the complaint. AFFIRMATIVE DEFENSE 6. That Defendant having refused to return subject office equipment to the Plaintiff for such reason that there was an oral agreement for the extension of Holding and Selling of the same for another six (6) months, as raised issues under paragraph 12 and 13;

ANSWER FOR ALTERNATIVE CAUSE OF ACTION 7. Assuming, arguendo, that Plaintiff will uphold the oral agreement, Defendant will only be entitled to return the contract price and will no longer be liable for the claimed legal interest.

COUNTERCLAIM 1. That, herein Defendant remains unpaid of his commission upon remitting the same dated January 16, 2013 in the amount of Eight Hundred Pesos (Php 800,000.00); 2. That due to unfounded suit filed by the said Plaintiff, Defendant suffered liquidated damages amounting to Fifty Thousand Pesos (Php 50,000.00); 3. That Defendant secured the services of a counsel and paid the amount of Thirty Thousand Pesos (Php 30,000.00) as and by way of attorneys fees. WHEREFORE, defendant prays for judgment: 1. Dismissing the complaint with costs against plaintiff; and 2. On the COUNTERCLAIM, ordering plaintiff to pay to defendant the sum of Eight Hundred Pesos (Php 800,000.00) for the unpaid commission of the Defendant; 3. Liquidated damages of Fifty Thousand Pesos (Php 50,000.00); Attorneys fees of Thirty Thousand Pesos (Php 30,000.00).

Other relief and remedies as may be deemed just and equitable under the premises are likewise prayed for. Quezon City, August 15, 2013.

PARK, KIM, PEREZ LAW FIRM Unit 8D, Madison Place, Cubao, Quezon City Contact Number: 419-37-28 Perez.kbiancaetal@gmail.com By: Atty. Katerina Bianca C. Perez Roll No. 385769 IBP No. 874986/02-14-2012/Quezon City PTR No. 95857639/01-15-2013/Quezon City MCLE: April 22, 2013

VERIFICATION

REPUBLIC OF THE PHILIPPINES ) QUEZON CITY ) S.S.

I, Mr. Mario Dinglasan, of legal age, Filipino citizen, single and resident 212 Sta Maria Street, Pasig City, Metro Manila, after having been duly sworn to in accordance with law do hereby depose and say: 1. That I am the defendant in the above-entitled case; 2. That I have caused the preparation of the foregoing Answer and have read the allegations contained therein; 3. The allegations in the said complaint are true and correct of my own knowledge and authentic records. IN WITNESS WHEREOF, I have hereunto affixed my signature this 15th day of August, 2013, in the City of Quezon.

Mr. Mario Dinglasan Affiant

SUBSRIBED AND SWORN, to before me this 15th day of August, 2013, in the City of Quezon, affiant exhibiting to me his SSS ID 34-1643658-8, affiant is identified by the notary public through his officially issued identified card, and who signed said document in my presence and sworn as to said document that he understood the contents thereof and that the same was his free and voluntary act and deed.

ATTY. Micky Park Notary Public Commission Expires: February 15, 2014 Roll of Attorney No. 382743 IBP No. 193746/4-21-2011/Quezon City PTR No. 3875649/01-22-2013/Quezon City

Doc No. Page No. Book No. Series of 2013.