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Answer with Cross-claim Sample

REPUBLIC OF THE PHILIPPINES


METROPOLITAN TRIAL COURT
City of Manila
Branch 1

XIAN LAO,
Plaintiff,

-versus- CIVIL CASE No. 12345

MATEO GO,
Defendant.
x---------------------------------------x

ANSWER WITH CROSS-CLAIM

COMES NOW, the defendant, through the undersigned counsel and unto this Honorable Court,
most respectfully avers:
1.That he ADMITS paragraph 2 of the complaint;
2.That he DENIES paragraph 3 of the complaint, the truth being that it was the defendant JOLO
TREVOR who applied for and exclusively benefited from the loan with the plaintiff, answering
defendant acting as mere co-signer in the promissory note to accommodate defendant
TREVOR and to guarantee the loan;
3.That he lacks knowledge or information sufficient to form a belief as to the truth of the
allegations contained in paragraphs 3, 4, and 5 of the complaint and therefore, specifically
DENIES the same;

SPECIAL/AFFIRMATIVE DEFENSES

4. That without the knowledge and consent of answering defendant, the principal condition of the
loan was changed and the term of payment thereof was unreasonably extended by the plaintiff, to the
prejudice of answering defendant;

5. That there was undue delay on the part of the plaintiff in enforcing the payment of the obligation,
and the loan could have been paid immediately at maturity had there been prompt and timely
notification to answering defendant of the non-payment of the loan by defendant TREVOR;

CROSS-CLAIM AGAINST HIS CO-DEFENDANT

6. That defendant TREVOR should reimburse answering defendant on any and whatever amount
the latter may be held answerable or which he may be ordered or suffered to pay under and by virtue
of the present action in favor of the plaintiff, answering defendant not having benefited whatsoever
from the loan which defendant TREVOR obtained from the plaintiff;

7. That defendant TREVOR should pay plaintiff directly and fully on the amounts claimed by the
latter in its complain he having benefited directly and exclusively from the transaction alleged in the
complaint;

WHEREFORE, premises considered, answering defendant respectfully prays to the Honorable


Court to render judgment as follows:
1.By dismissing the complaint against answering defendant;
2.By ordering defendant TREVOR to pay directly and fully to the plaintiff the amounts claimed
by the latter in the complaint;
3.By ordering defendant TREVOR to pay answering defendant for any and whatever amounts
the latter may be held liable to or be ordered or suffered to pay plaintiff under and by virtue
of the plaintiffs claim in the present action.
Answering defendant prays such other relief and remedies as may be deemed just and equitable
under the premises.

City of Manila, October 1, 2012.

MORALES AND ASSOCIATES LAW OFFICE


Counsel for the Defendant Mateo Go
Suite 109 Morales Tower
Paco, Manila

By:
ZEUS MORALES
Roll No. 12345
IBP No. 23456/1-18-2012
PTR. No. 34567/1-18-2012

VERIFICATION / CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines )


City of Manila ) S.S.

I, MATEO GO, of legal age, Filipino citizen, single and resident of 234 San Bartolome St., Manila,
after having duly sworn to in accordance with law, do hereby depose and say that:
1. 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 said answer are true and correct of my own knowledge and based on
authentic records;
4. I hereby certify that I have not commenced any other action or proceeding involving the same
issues in any court, tribunal or quasi-judicial agency and, to the best of my knowledge, no such
other action or claim is pending therein;
5. If I should thereafter learn that a similar action or proceeding has been filed or is pending, I
hereby undertake to report that fact within five (5) days therefrom to the court or agency where
the original pleading and sworn certification contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of the foregoing facts and to comply
with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 1st day of October 2012, in
the City of Manila.

MATEO GO

SUBSCRIBED AND SWORN TO before me this 1st day of October 2012, in the City of Manila,
affiant exhibiting to me his SSS ID No. 123456 issued on January 5, 2012.

Doc. No. _______


Page No. _______
Book No. _______
Series of 2012.

Copy furnished:
ATTY. JADE GAYONDATO
Counsel for the Plaintiff
Unit 876 Gayondato Bldg.
Pandacan, Manila

JOLO TREVOR
Defendant
123 Singalong St.
Manila

EXPLANATION

Copy of the ANSWER was served by registered mail due to time and distance constraints and
for luck of the undersigneds staff who can serve the same in person.

ZEUS MORALES