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ANSWER
DEFENDANT, by counsel, most respectfully submit his Answer to
plaintiffs complaint unto this Honorable Court and in support aver that:
1. Defendant admits the allegations contained in paragraph 1, 2 and 3 of the
complaint.
2. Defendant is without knowledge or information to form a belief as to the
truth of the allegations in paragraph 4 of the complaint.
3. Defendant admits the allegations in paragraph 4 of the complaint except
plaintiffs false assertion that they paid Php.10, 000.00 as reservation fee.
The defendant just agreed to reserve 2 lots for the plaintiff without collecting
a reservation fee because of the plaintiffs were referred to him by his close
PRAYER
WHEREFORE, PREMISES CONSIDERED, it is most respectfully prayed
that after hearing on the merits, this Honorable Court issue an Order:
1. Dismissing the Complaint in toto for utter lack of merit;
2. Granting moral damages in favor of the Defendant in the amount
of one hundred thousand pesos(P100,000.00);
3. Granting exemplary damages in favor of the Defendant in the
amount of one hundred thousand pesos(P100,000.00);
MELODY
Counsel for the Plaintiff
PTR No. 18909595:1-04-07:S.C.
IBP No, 693095:1-04-07:S.C.
MCLE No. 6877900
Roll No. 42481:5-10-97
Rm. 4 2/F Heritage Building
Malvar, Santiago City
CP #: 0926-975-0579
E-mail address: melody_mangaoil@yahoo.com
VERIFICATION AND CERTIFICATION
AGAINST FORUM SHOPPING
I, the undersigned after being sworn to in law, hereby depose and say:
That I caused for the preparation of the same and that all the allegations
contained thereon are true to our knowledge and belief;
That I have not commenced any action or filed any claim involving the same
issues in any court, Tribunal or quasi-judicial agency and to the best of my
knowledge, no such actions in pending thereon; and if we should thereafter learn
that the same or similar actions has been filed or pending, we shall report the fact
within FIVE (5) days therefrom to the court wherein this complaint is filed.
NELSON VIDASCO
SUBSCRIBED and SWORN to before me this 14th day of February, 2014
in Santiago City.
I SET MY HAND AND NOTARIAL SEAL
JIZEL
Notary Public
PTR No. 18909595:1-04-07:S.C.
IBP No, 693095:1-04-07:S.C.
MCLE Exemption No.67880
Roll No. 42481:5-10-97
Rm. 4 2/F Heritage Building
Malvar, Santiago City
CP #: 0917-567-8905
E-mail address: jizel@gmail.com