REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Manila
Branch 56

SARAH LIN DE SILVA,

Plaintiff,

-versus- CIVIL CASE NO. 12345

FOR: EJECTMENT
LOUIE MERCADO,
Defendant.

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ANSWER

COMES NOW, the defendant, through the undersigned

counsel and unto this Honorable Court, most respectfully avers:

1. That he SPECIFICALLY DENY the contents of paragraph (4)

that plaintiff allowed defendant to temporarily used her land
until such time when the defendant would be able to buy his
own land;

2. in fact they have entered in a agreement executed in written

document that they have entered in a lease agreement subject
to terms and conditions;

3. That the written agreement attached herein marked as

annexed “1”;

4. That, the written agreement states that SARAH LIN DE SILVA

agrees to lease her land to LOUIE MERCADO according to the
terms and condition set forth herein;

a. Tenant will pay the Landlord a monthly rent of PhP

10,000.00 (TEN THOUSAND PESOS ONLY) for the term.
 Rent will be payable and due on the 5th day of each
month during the term.
b. Rent paid after 5th day of each month will be deemed as
late; and if rent is not paid within 10 days after such due
date, tenant agrees to pay a late charge of PhP 1,000.00
(ONE THOUSAND PESOS ONLY)
c. Tenant will deliver and surrender to Landlord possession
of the Premises immediately after the expiration of the
term or the termination of this agreement;
d. All notices given under this agreement must be in
writing. A notice is effective upon receipt and shall be
delivered in person, thru personal service no other than
the Landlord herself or the Tenant himself;
e. This agreement will be for a term beginning on February
19, 2014 and ending on December 31, 2019.

5. That he SPECIFICALLY DENY the contents of the demand

letter on paragraph (5);

6. That the demand letter does specifically states the reason for
the ejectment or for non compliance of monthly dues.

7. That he had religiously complied his obligation to pay his

monthly dues and pay the necessary penalty when the
defendant fails to pay his due timely;

8. That he has the following receipts that he had paid his

monthly dues. (attached herein as annexes “2-01 to 2-48”)

9. That the defendant had not breach any agreement with

respect to the written agreement they have executed.

10. That the defendant sees no reason to be evicted.

WHEREFORE, the defendant respectfully prays that the

complaint be dismissed with costs against the plaintiff. Other relief
and remedies as may be deemed just and equitable under the
premises are likewise prayed for.
City of Manila, May 29, 2018.

MAPAGMAHAL LAW OFFICE

Counsel for the Defendant
Suite 258 The Tower
Malate, Manila

By:
ATTY. LADY GRACE YANDOC
Roll No. 98765
IBP No, 12345/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila

Copy furnished:
ATTY. ANTHONY GO
Counsel for the Plaintiff
Unit 1234 Laurel Building
Sampaloc, Manila

EXPLANATION

Copy of the foregoing ANSWER was served to plaintiff’s

counsel by registered mail due to time and distance constraints and
for lack of the undersigned’s staff who can serve the same in
person.

LADY GRACE YANDOC