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Republic of the Philippines

FIRST MUNICIPAL CIRCUIT TRIAL COURT OF ARORO-BALENO


Fifth Judicial Region
Aroroy, Masbate

LOVELY TUBAY,
Plaintiff,

CIVIL CASE NO. 0010125

- versus -

- for

ROSELYN CUSPAO,
Defendant.
X---------------------X

COLLECTION OF SUM OF
MONEY WITH DAMAGES

ANSWER
The Defendant, by the undersigned counsel, to this Honorable Court and in answer to the
Plaintiffs complaint, most respectfully aver:
1. That the Defendants admit the allegations contained in paragraph 1 of the complaint
but deny the allegations contained in paragraphs 2, 3, and 4 of the same having no
knowledge sufficient to form a belief as to the truth and veracity of the same, the true
facts being embodied in the special and affirmative defenses of this answer; and
2. That they likewise deny the allegations contained in paragraphs 5 and 6 of the
complaint for being speculative and baseless under the circumstances.
SPECIAL AND AFFIRMATIVE DEFENSES
1. That the complaint states no cause of action;
2. That no sale ever transpired and that the promissory note issued to Ms. Tubay was a
fabricated document and the defendants signature forged.
3. That in order to protect the rights and interests of the defendants, they solicited the
services of counsel for which they obliged themselves to pay the sum of Fifteen
Thousand Pesos ( P15,000.00) as acceptance for attorneys fee plus Five Thousand
Pesos ( P5,000.00 ) per appearance in court of counsel and they incurred and will
incur the sum of Ten Thousand Pesos ( P10,000.00) as litigation expenses for which
these amounts should be reimbursed by the plaintiff; and
4. That by reason of the filing of this instant action, the defendants had suffered mental
anguish, wounded feelings, sleepless nights, serious anxities and other similar
sufferings for which the same could be atoned by condemning the plaintiff to pay
them the sum of Twenty Thousand Pesos ( P20,000.00 ) as moral damages and to give
a lesson to the plaintiff and to deter others from doing the same act, a further sum of
Ten Thousand Pesos ( P 10,000.00 ) as sundry litigation expenses.

WHEREFORE, premises considered, it is most respetfully prayed that judgment issue in


favor of the defendants and against the plaintiff, the following:
a. Ordering the dismissal of the complaint with costs against the plaintiff;
b. Ordering the plaintiff to pay the defendants the following sums: Twenty Thousand
Pesos ( P20,000.00 ) as moral damages; Ten Thousand Pesos (P10,000.00 ) as
exemplary damages; Fifteen Thousand Pesos ( P15,000.00) as acceptance for
attorneys fee plus Five Thousand Pesos ( P5,000.00 ) per appearance in court of
counsel and Ten Thousand Pesos ( P10,000.00) as sundry litigation expenses; and
c. Such other reliefs and remedies just and equitable in the premises.
Aroroy, Masbate, February 25, 2015.
LANIE C. LAURIO
Counsel for the Defendants
Roll of Attorney No. 56567
IBP O.R. No. 654321 (11/20/15)
PTR O.R. No. 0134876(10/10/14)
Aroroy, Masbate
MCLE No. 145879 (01/08/14)

Copy furni

CERTIFICATION
I, ROSELYN C. CUSPAO, Filipino, of legal age, resident of Poblacion, Aroroy, Masbate,
Philippines, under oath, hereby depose and say: I am the defendant in the above-entitled case;
that I have caused the preparation and filing of the foregoing answer; that I have read and
understood all the allegations contained therein and that the same are true and correct to the best
of my knowledge and belief.
Aroroy, Masbate, February 25, 2015.
ROSELYN C.CUSPAO
Defendant
SUBSCRIBED AND SWORN to before me this 25th of February 2015 at Aroroy,
Masbate, Philippines.

LANIE C. LAURIO
Roll of Attorney No. 56567
IBP O.R. No. 654321 (11/20/15)
PTR O.R. No. 0134876(10/10/14)
Aroroy, Masbate
MCLE No. 145879 (01/08/14)

Copy furnished:
Atty. HILDA ANGELIE BERNAL
Counsel for the Plaintiff
Aroroy, Masbate