Académique Documents
Professionnel Documents
Culture Documents
Plaintiff,
For: Collection of Sum of
JOBERT CHAN,
Defendant.
x--------------------------------x
ANSWER
1. Paragraphs one (1) and two (2) of the Complaint are admitted;
2. Paragraphs three (3) to five (5) of the Complaint are denied for lack
known only to and are within the control only of the plaintiff;
that the defendant owes the plaintiff a sum of money and fails to
pay the same, the truth being those alleged in the special and
1. The Defendant and the Plaintiff are not business partners but only
2. The Defendant paid the Plaintiff the amount that the Plaintiff
3. The Plaintiff and his wife indeed, reduced the amount of the loan
but the defendant paid the loan through his wife, in full.
COMPULSARY COUNTERCLAIM
appearance;
(100,000.00).
PRAYER
WHEREFORE, PREMISES CONSIDERED, it is respectfully
lack of merit with costs against the plaintiff; and that the
By:
JOEY DE LEON
SHOPPING
and have read the allegations therein, and that they are true and
authentic documents;
3. I have not commenced any other action or proceeding involving the
JOBERT CHAN
Affiant
her identity.
JOEY DE LEON
Notary Public
Doc. No.: 49
Page No.: 8
Book No.: II
Series of 2011
Republic of the Philippines
Plaintiff,
For: Collection of Sum of
JOBERT CHAN,
Defendant.
x--------------------------------x
MOTION TO DISMISS
DISCUSSION
2010. Copies of the said Summons and Return of Service that form
part of the records on the case are hereto pleaded as integral part
of this Motion;
provided for under the said Section, as service was done only on an
JOEY DE LEON
Notary Public
Plaintiff,
For: Collection of Sum of
Defendant.
x--------------------------------x
COMPLAINANTS INTERROGATORIES
INSTRUCTIONS
event that you are able to provide only part of the information
information you are able to provide and state the reason for your
NOTE
ASPECT.
INTERROGATORY.
COMPLAINANTS INTERROGATORIES
22 January 2011
WILLIE REVILLAME
Plaintiff,
For: Collection of Sum of
JOBERT CHAN,
Defendant.
x--------------------------------x
2010;
b. Loan Certificate issued by plaintiff dated 30 July 2010;
c. Business Registration of Joke Time Business filed on 23
June 2010.
house
RTC - Branch 2
Quezon City
Greetings!
ATTY. BONGBONG SY
Copy furnished
ATTY. AB CD
ATTY. BONGBONG SY
Republic of the Philippines
Plaintiff,
For: Collection of Sum of
JOBERT CHAN,
Defendant.
x--------------------------------x
I.
II.
Quezon City;
of the Court;
3. That the above-named spouse of Plaintiff is the
2009;
made for his own personal use. That despite demands, defendant
(P98,700.00);
for thirty six (36) months, in the form of cash from February 2008
Agreement.
11. That on June 1, 2008 a final demand letter was sent to
(P26,000.00);
fails and refuses to heed to the formers just and valid demands,
leaving the plaintiff no other recourse but to litigate and file this
acton.
P5,000.00;
III.
IV.
DOCUMENTS TO BE PRESENTED
V.
WITNESSES TO BE PRESENTED
VI.
agreed upon in open court at such dates and time convenient to the
unto this Honorable Court that the foregoing Pre-Trial Brief be duly
noted.
(SGD.) ATTY. MI MI
Counsel for Petitioner
Address: #11 Malaya St., People's Village, Quezon City
Contact Nos.: (054) 887-1476; 0917-449-3285
Roll No. 97871
PTR No. 024542; 1/10/09; Quezon City
IBP No. 007308; 12/20/09; Quezon Chapter
(SGD.) ATTY. MO MO
Counsel for Petitioner
Address: #23 Malaya St., People's Village, Makati City
Contact Nos.: (054) 887-1234; 0917-468-5475
Roll No. 97963
PTR No. 0257442; 3/11/08; Makati City
IBP No. 478521; 2/2/09; Makati Chapter
(SGD.) ATTY. MU MU
Counsel for Petitioner
Address: #8 Malaya St., People's Village, Makati City
Contact Nos.: (054) 897-3256; 0918-147-6985
Roll No. 85213
PTR No. 0285242; 5/4/08; Makati City
IBP No. 478521; 5/2/09; Makati Chapter
Copy furnished:
DE LEON & ASSOCIATES
Counsel for Respondent
Address: 10/F Commerce Centre, Valero St., Quezon City
Contact Nos.: (081) 874-1478 to 90
EXPLANATION
(SGD.) ATTY. MI MI
Counsels for Petitioner
Doc. No. 4;
Page No. 7;
Book No. XV;
Series of 2011.
Republic of the Philippines
Plaintiff,
For: Collection of Sum of
JOBERT CHAN,
Defendant.
x--------------------------------x
JUDICIAL AFFIDAVIT
OF
1. Do you swear to tell the truth and nothing but the truth?
I do.
2. Are you aware that you may face criminal liability for false
testimony or perjury if you will not tell the truth?
I am.
4. Are you the same Bogart XXX, the Petitioner in this case?
Yes.
Bogart XXX
Affiant
ATTESTATION
I hereby state, under oath, that I faithfully recorded the questions I
asked and the corresponding answers that the witness gave and
that neither I nor any other person present or assisting me has
coached the witness regarding the latters statement.
ATTY. WILLIE REVILLAME
Doc No. 8;
Page No.9;
Book No. XV;
Series of 2011.
Copy Furnished:
Office of the City Public Prosecutor
Quezon City