Vous êtes sur la page 1sur 3

REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT


City of Iloilo
BRANCH 1

LYRA ANN G. BELITA,


Plaintiff,

-versus- For: Unlawful Detainer


Civil Case No. 553-231
PETER B. CHAN,
Defendant.
x------------------------------------x

ANSWER

COMES NOW, Defendant PETER B. CHAN, by the undersigned counsel, in the


above-entitled case and before this Honorable Court most respectfully submits this
ANSWER and aver that:

STATEMENT OF THE CASE

1. That the plaintiff, LYRA ANN G. BELITA, is of legal age, Filipino citizen, single, with
residence and postal address at 24 Block, Brgy. Bolilao, Iloilo City;

2. That the defendant, PETER B. CHAN, is of legal age, Filipino citizen, single, with
residence and postal address at Brgy. Villa Anita, Iloilo City, where he may be served with
summons and other court processes;

3. That this is a case for Unlawful Detainer founded allegedly on Plaintiffs’ claim of that
defendant’s failure to pay the rentals for the leased residential building that the plaintiff
required;

ADMISSIONS AND DENIALS

4. Defendant admits Paragraphs 1 and 2 of the Complaint in so far as the personal


circumstances of the parties involved;

5. Defendant admits paragraphs 3 and 4 in connection with entering into a lease contract
with the plaintiff.

6. Paragraph 5 and 6 of the complaint is admitted with qualification. The plaintiff


erroneously told this court that the defendant failed to pay the agreed rental starting from
July 3, 2018 up to present. The defendant only failed to pay the rentals starting from the
month of November 3, 2018 because the said residential building was damaged by a
typhoon that struck the City of Iloilo on July 1, 2018. Defendant had to make necessary
repairs damaged by the typhoon, in order to make the place habitable. This is because the
plaintiff, despite the defendant’s demand, ignored to make the necessary repairs over his
building;

7. Defendant specifically denies paragraphs 7 and 8 because of the fact that there was a
mutual agreement between the parties for the defendant to use his rentals for the months of
July to October 2018;

PRAYER

WHEREFORE, premises considered defendant, most respectfully prayed of this


Honorable Court that judgement be rendered:
a) Dismissing the complaint for utter lack of merit and cause of action.

b) Ordering the plaintiff to pay the defendant moral damages, attorney’s fees
and cost of litigation as prayed for in the preceding paragraph, and

c) And such other relief as may be deemed just and equitable under the
circumstance.

Iloilo City, Philippines, March 26, 2019.

ATTY. JILLEN A. SUAN


Counsel for the Defendant
Arguelles Bldg., Jaro, Iloilo City
Roll No.: 110928
PTR No.: 1112345 06-30-2018 Iloilo City
IBP No.: 176184 06-30-2018 Iloilo City
MCLE Compliance No.: 455813 08-05-2018

VERIFICATION/CERTIFICATION

I, PETER B. CHAN, of legal age, Filipino citizen, single, with residence and postal
address at Brgy. Villa Anita, Iloilo City, after having been duly sworn in accordance with
law, hereby depose and state:

a) I am the defendant in the above captioned case; I have caused the


preparation of the foregoing answer;
b) I have read the allegations contained therein; and

c) I certify that they are all true and correct of my personal knowledge
or based on authentic records.

In witness whereof, I have hereunto set my hand this 26th day of March 2019 at
Iloilo City, Philippines.
PETER B. CHAN
Affiant

SUBCRIBED AND SWORN TO before me this 26th day of March 2019 in Iloilo
City, Philippines, affiant exhibiting to me her PRC I.D. no. 123456 issued in Iloilo
City on June 30, 2005 and valid until June 30, 2020.

SHANE MARIE BELLOGA–EDROSOLANO


Notary Public for the City & Prov. of Iloilo
Until December 31, 2019
Arguelles Bldg., Jaro, Iloilo City
Roll No.: 110928
PTR No.: 1112345 06-30-2018 Iloilo City
IBP No.: 176184 06-30-2018 Iloilo City
MCLE Compliance No.: 455813 08-05-2018
Doc. No. 28;
Page No. 6;
Book No. 1;
Series of 2019.

Copy furnished:

ATTY. LEONEL O. OCANA


Counsel for the Plaintiff
Varona Law Office, Alta Tierra Village
Jaro, Iloilo City

Vous aimerez peut-être aussi