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COUNTERCLAIMS
In the rare event that the Honorable Court shall resolve to proceed with the
trial of the case despite the above special and affirmative defenses, the
Defendant submit the following compulsory counterclaims and for this
purpose, hereby restate and repleads all the allegations in the preceding
paragraphs by way of reference and incorporation:
1. Due to the plaintiff’s willful and patent disregard of the
defendants’ rights, the defendants suffered inconvenience,
embarrassment and humiliation thereby causing them mental
anguish, serious anxiety, wounded feelings and social
humiliation, resulting in moral damages for which the plaintiff
should be held liable in the amount of One Hundred Fifty
Thousand Pesos (P150,000.00), Philippine currency;
PRAYER
3. In the remote event that the Honorable Court shall proceed with
the trial, the defendant pray for a judgment denying the reliefs prayed for by
the plaintiff for lack of merit;
Other reliefs just and equitable under the premises are likewise prayed
for.
LeBron James
IBP No. 12345/1-1-1111/ Muntinlupa City
PTR No. 12345/1-1-111/ Muntinlupa City
Roll No. 12345
MCLE Compliance No. III-12345-11
Jesus James
IBP No. 12345/1-6-3444/ Muntinlupa City
PTR No. 123456/1-6-4455/ Muntinlupa City
Roll No. 532233
MCLE Compliance No. III-012334/1-25-2011
3. I read all the allegations thereof and that the same are true and
correct based on my own personal knowledge and authentic records;
Doc. No._____;
Page No._____;
Book No._____;
Series of 2018.