answer 2
DESCRIPTION
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Republic of the PhilippinesProvince of IloiloMUNICIPAL TRIAL IN THE CITIESIloilo City
A CIVIL CASE NO. For: Collection Plaintiff,
-versus-
BDefendant.x------------------------------------------x
ANSWER TO THE COMPLAINT
COMES NOW defendant B, through the undersigned counsel and to this Honorable Court, most respectfully alleges:
1. Defendant admits having incurred loan obligation to herein Petitioner sometime in June 2014 for an amount of P150,000 payable within six months.2. Defendant respectfully submits that such loan obligation has already been settled as evidenced by an acknowledgement receipt issued by A on December 27, 2014 in favor of B.
AFFIRMATIVE DEFENSES
3. The collection suit filed by A against herein Defendant cannot prosper for the same was already settled.4. The existence of acknowledgement receipt is a proof of the settled obligation which A cannot deny.PRAYERWHEREFORE, Defendant respectfully Prays that the case be decided in favor of the defendant and be dismissed.Defendant also prays for other reliefs and remedies as the court may deem it just and equitable.
Iloilo City Manduriao, Iloilo, Philippines, April 15, 2015. LADRIDO and GO and AssociatesCounsels for Respondent-Appellant 3nd Floor LBC BuildingDelgado Streets, Iloilo CityE-mail address: [email protected]. No. (033) 3377765565 & (033) 3371146
By:
Joefrey S. UyIBP NO.000990 Jan. 2, 2015 / ILOILO CITYPTR NO. 000808 Jan. 3, 2015/ ILOILO CITYATTORNEYS ROLL NO. 101Copy furnished:
Atty. Juan De La CruzRegistry Receipt No.4343434Counsel for PlaintiffsDel Rosario Law OfficeDoor 1, Del Rosario Building16 Libertad St., Jaro, Iloilo CityDate: April15, 2015EXPLANATION(Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure)
Personal service cannot be effected upon Atty. Douglas Kramer at Del Rosario Law Office, Door 1, Del Rosario Building 16 Libertad St., Jaro, Iloilo City due to the distance between the said address and the office of the undersigned counsels hence copy of this Answer with Counterclaim is being served upon him through registered mail with return card.
Joefrey S. Uy (sgd.)
VERIFICATION & CERTIFICATION ON NON-FORUM SHOPPING
ACKNOWLEDGEMENT RECEIPT
December 27, 2014
I hereby acknowledged the receipt of P150,000 from B for the payment of the latters obligation on June 2014.
A (sgd.)