REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
BRANCH 33
ILOILO CITY
ANTONETTE C. CARO
Plaintiff,
CIVIL CASE NO. 12987
-versus-

FOR: COLLECTION OF
SUM OF MONEY

JOHN REY D. ABADA

Defendant,
x-----------------------------------------x
ANSWER

NOW COMES the defendant in the above entitled case, and to this
Honorable Court most respectfully alleges:
1. Defendant admits the averment in paragraph 1, 2 and 3 of the
complaint;
2. Defendant specifically denies the allegation in paragraph 4 of
the complaint, the truth being that the obligation has been paid
already;
3. Defendant has no knowledge or information to form a belief as
to the truth of the averment in paragraphs 5,6 and 7 of the
complaint;
By way of special and affirmative defenses, defendant avers:
1. That the obligation has been paid;
2. That the defendant had purchased said land from plaintiff and
paid said promissory notes;
3. That the cause of action has prescribed.
1

By way of counterclaim, defendant alleges:

1. That by virtue of this unwarranted and malicious act initiated by
the plaintiff, defendant was forced to engage counsel in the sum
of P10,000.00.
WHEREFORE, it is respectfully prayed that the complaint be
dismissed and defendant be awarded the amount of P5,000.00.
Other equitable reliefs are likewise prayed for.
Iloilo City, Philippines, January 10, 2017

SHANE MARIE BELLOGA - EDROSOLANO

Counsel for the Defendant
Arguelles Bldg., Jaro, Iloilo City
Roll No.: 110928
PTR No.: 1112345 06-30-2016 Iloilo City
IBP No.: 176184 06-30-2016 Iloilo City
MCLE Compliance No.: 455813 08-05-2016

VERIFICATION AND CERTIFICATION

I, JOHN REY D. ABADA, of legal age, married, Filipino and a

resident of Brgy. Buhang., Jaro, Iloilo City, under oath depose and
state that:
a) I am the defendant in the above captioned case; I have
caused the preparation of the foregoing answer;
b) I have read the allegations contained therein; and
c) I certify that they are all true and correct of my personal
knowledge or based on authentic records.
In witness whereof, I have hereunto set my hand this 10 th day of
January 2017 at Iloilo City, Philippines.
JOHN REY D. ABADA
SUBCRIBED AND SWORN TO before me this 10th day of
January 2017 in Iloilo City, Philippines, affiant exhibiting to me her
PRC I.D. no. 123456 issued in Iloilo City on June 30, 2016 and valid
until June 30, 2018.
SHANE MARIE BELLOGAEDROSOLANO
Notary Public for the City & Prov. of Iloilo
Until December 31, 2018
Arguelles Bldg., Jaro, Iloilo City
Roll No.: 110928
PTR No.: 1112345 06-30-2016 Iloilo City
IBP No.: 176184 06-30-2016 Iloilo City
MCLE Compliance No.: 455813 08-05-2016
Doc. No.
Page No.
Book No.
Series of 2017
Copy furnished:
ATTY. JAYSON D. LOCSIN
Counsel for the Plaintiff
2nd Floor RCBB Building
Jaro, Iloilo City