REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH __, MANDALUYONG CITY

SALVADOR CHUA,
Plaintiff,

- versus - CIVIL CASE NO. __________

For: COLLECTION OF SUM
OF MONEY WITH
DAMAGES

RODRIGO RIVERA,
Defendant.
x----------------------x

ANSWER

COMES NOW, Defendant, by the undersigned counsel,

and unto this Honourable Court, most respectfully avers:

1. That he DENIES the contents of paragraph 2 insofar

as his personal circumstances are concerned;

2. That he DENIES that he has an obligation in paying

the loan as cited in the contents of paragraph 3;

3. That he DENIES that he issued checks as payment

for paying off the loan as cited in the contents of
paragraph 3;

4. That he contends that he is a victim of identity theft

and that the person who transacted with the plaintiff
is an impostor;

5. That he never intended to enter into a loan

transaction with the plaintiff, and that he never
intended to pay off a loan that he never acquired in
the first place;

6. That he suffered sleepless nights and damaged

reputation as a result of the complaint.
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 PRAYER

WHEREFORE, the defendant respectfully prays:

1. That the complaint be dismissed with costs against the

plaintiff;

2. That plaintiff pays him moral damages for the amount of

Php 25,000.00;

3. That plaintiff pays the attorney’s fees and litigation

expenses for the amount of Php 25,000.00.

Other relief and remedies as may be deemed just and

equitable under the premises are likewise prayed for

City of Mandaluyong, Philippines, May 17, 2019.

BY:

JOB BUDS M. MARATA

Counsel for the Defendant
Attorney’s Roll No. 185492
IBP No. 126574, 01/05/20, City of Manila
PTR No. 88129, 01/05/20, City of Manila
MCLE Compliance No. IV-008465, 7/21/15
1/F, Birch Tower Condominium,
1622 J. Bocobo St., Malate, City of Manila
Email add.: budz.marata@gmail.com

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 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.