Republic of the Philippines

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 1, Baguio City

FAYE MAKILING, JULIUS ERVING

BRITISH BULLDOG, JIMMY PAGE,
HORNY PETER, CONOR MCGREGOR
PlaintiffS,
Civil Case No.: 1234-PWT
- versus –
FOR INJUNCTION with
Application of Preliminary
Injunction and prayer for
the immediate ex-parte
issuance of a
TEMPORARY
RETRAINING ORDER
(TRO)
BIKO ALBERTO
Defendant.
x---------------------------------x
DONNA SLAB, et al,
Intervenors,
x---------------------------------x
SECK SUAL TSOKOLATE, et. Al,
Intervenors.
x---------------------------------x

ANSWER-IN-INTERVENTION
WITH AFFIRMATIVE DEFENSES

With utmost deference to this Honorable Court, the defendant most

respectfully states that:

1. With the exception of the last two (2) paragraphs of item no. 1 of the complaint-in-
intervention of DONA SLAB. et. al, defendant will admit the allegations as to the
 personal cicumstances of the intervenors and that they are both holders at the
HOWNEY LADIES gastropub and Inn at 234 Jewel Street, Baguio City,
Philippines.
2. In the complaint-in-intervention of SECK SUAL TSOKOLATE et. Al, she likewise
admits the allegations in item no. 1 of the complaint-in-intervention as to the
personalcircumstances of the intervenors. She likewise admits that the intervenor,
BAD GUYS MARKETING COOP. is a supplier for HOWNEY LADIES
gastropub and Inn and that all the intervenors were issued business permits, she will
deny the other allegations in item no. 1 of the complaint-in-intervention.
3. With the exception of the second paragraph of item no. 4, she will admit the
allegations in item nos. 2 and 3 of the complaint.
4. She will deny the allegations in item no. 4 of the complaint for want of knowledge
sufficient to form belief as to the truth or falsity of the same.
5. She will deny the allegations in item no. 5 of the complaint, the appropriation
ordinance referred to in item no. 5 of the complaint reflects the amount appropriated
for the operation of HOWNEY LADIES gastropub and Inn in the amount of
P1,234,234,535,646.32. It is actually the amount that the city expects to spend for
operation of the HOWNEY LADIES gastropub and Inn for the year 2020 contrary
to what is being implied in the complaint that it is the income from the HOWNEY
LADIES that is included in the Performance Budget of the City for the year 2020.
6. Save for the terms as defined under the National Building Code, she will deny the
allegations in item no. 6 of the complaint, the physical composition of the facility
complies with fire safety standards and consists of emergency exits and fire exits.

PRAYER
WHEREFORE, it is respectfully prayed of the Honorable Court, after due notice
and hearing:
a. To lift the temporary restraining order (TRO);
b. To deny issuance of the writ of preliminary injunction and dismiss the
complaint.
The defendant further prays for such further relief, just and equitable in the premises.
Baguio City, Philippines, April 16, 2020

ATTY. DIHMA PASUKAN

City Prosecutor of Baguio
 Baguio City Tel No.: (074) 442-3122
PTR No. 684622341233, 04-30-18
IBP O.R. No. 3412099, 4-16-18
Roll No. 86355, 04-29-18

Copy Furnished:

ATTY. JUAN MIGUEL V. ALBERTO VI

Counsel for the Plaintiffs and Intervenors
Baguio City Tel No.: (074) 442-3322
PTR No. 684623, 04-30-18
IBP O.R. No. 3412099, 4-16-18
Roll No. 86355, 04-29-18

EXPLANATION
(Pursuant to Sec. 11, Rule 13 of the 1997 Rules of Procedure)

The foregoing answer-in-intervention was copy furnished to the intervenors

counsel by Registered Mail due to a sudden gastroenteritis outbreak within
the available personnel to effect personal service and filing.

ATTY. DIMAH PASUKAN