Republic of the PhilippinesRegional Trial Court

Calamba City, Laguna

Rogelio E. Micosa IS NO.Complainant,

FOR: ESTAFA-versus-

Sps. Reynante and Maryjane RamosRespondent

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COUNTER-AFFIDAVIT

DEFENDANTS, by the undersigned attorney and to this Honorable

Office respectfully avers that:

1. Defendant admits paragraph 1 with regards the names, residences

and status of the parties, but refutes portions of other paragraphs, for

lack of adequate knowledge to form as to the truth thereof.

2. Defendants denies particularly paragraph two (2)a, b, and c, claiming

that an agreement to lend money to some farmers was entered into by

the plaintiff and the defendants, and a certain amount of two hundred

thousand pesos (P200,00.00)was sent to Mrs. Susana Macamus the

mother of Maryjane Ramos. No promissory note was issued nor

given to the said remittance.

3. Defendants rejects also the contention of the plaintiff that she

personally gave the amount of forty seven thousand pesos

(P47,000.00) to the defendants and denies further that the said

amount was used for our own personal use/consumption because of

the fact that the defendants never received such figure.

4. Defendant also denies the authenticity of the “sinumpaang

salayasay” attached to the complaint as “ANNEX C” stating the

existence and amount. There was no written or verbal agreement

entered into by the plaintiff and the defendants.

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WHEREFORE, defendant respectfully prays that the complaint be

dismissed due to lack of merit, with costs against the plaintiff.

ATTY. GAUDENCIO A. CATUBAO JR.

Counsel for the Defendant

140-B Real Street, Calamba City

PTR NO. 7484788/02/04

IBP OR# 143478 /11/03/09

Attys. Roll No. 62455/ May 10, 2009

MCLE COMPLIANCE NUMBER III-4874

/11/7/2014

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