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ANSWER/REPLY
(to Respondent’s Memorandum of Appeal)

Complainant-appellee, through undersigned counsel, respectfully

allege the following:

1. Complainant-appellee, through
counsel, received the
Respondent-appellant’s
Memorandum of Appeal on 28
June 2018 via registered mail.
This reply is filed within ten (10)
days from receipt of such
Memorandum of Appeal thus
filed on time.

2. Complainant-appellee admits
paragraphs 1.

3. Complainant-appellee admits
paragraph 2 except the date of
receipt by respondent/appellants
for lack of knowledge as to the
truth or falsity thereof.

4. Complainant-appellee admits
paragraph 3 only insofar as they
are the grounds being relied
upon by the respondent
appellant.

5. Complainant-appellee admits
paragraphs 4 and 5.

6. Complainant-appellee admits
paragraphs 6 and 7 only insofar
as to the existence of the
attachments cited thereon.

6.1 Since the respondent-appellant posted a surety bond, the rules

require certain attachments to accompany the memorandum of
appeal in order for the appeal to be perfected.
6.2 The rules, among others, require the original or certified true
copy of the Certificate of Regulation of the bonding company
issued by the Securities and Exchange Commission (SEC).
6.3 Upon checking the attached document issued by the Securities
and Exchange Commission, the surety company named in the
document is Eastern Assurance and Surety Corporation. The
surety company engaged by the respondent-appellant is
Milestone Guaranty & Assurance Corporation. Thus, the
Certification from SEC required by law is lacking.