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REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT Branch 01 Iligan City Ahwat Zaman, Plaintiff, -versusCivil case No.

2345 For: Unlawful Detainer Pedro Skywalker, et. al, Defendant -----------------------------------x ANSWER Defendant, through the undersigned counsel, unto this Honorable Court, most respectfully allege: 1. That defendant admit the allegation of paragraph 1 of the complaint as to the status and residences of the parties; 2. That the defendant admit the allegation of paragraph 3 of the complaint that the defendant took occupancy of the apartment by virtue of the leased contract as ANNEX 1.

3. That the defendant denied the allegation of paragraph 4, because the plaintiff refused to received the monthly payment in the month of October and November for no reason.
4. That the defendant denied the allegation in paragraph 5 of the complaint

because defendant pay all the rentals which demanded by the plaintiff in his demand letter, but not stated to vacate the leased premises of said demand letter. Copy of said demand letter which defendant received on December 15,2009 as ANNEX 2.

BY WAY OF AFFIRMATIVE DEFENSES: That the defendant replead the foregoing allegations and further allege: 5. That the plaintiff have NO CAUSE OF ACTION against the answering defendants; 6. That in fact, defendant offered to pay the monthly rentals of October and November as obligations from plaintiff but the latter refused to received the said payment.

BY WAY OF COMPULSORY COUNTERCLAIM 7. That by reason of this unfounded suit, defendants were constrained to hire the services of counsel to help them defend their rights and agreed to pay the sum of P50,000.00 as attorneys fee, excluding the appearance fee of P2,000.00 per hearing; 8. That because of the malicious filing of this case by the plaintiffs, the defendants were subjected to shame, humiliation, embarrassment, besmirched reputation, anxiety, several sleepless nights, taint their honor and integrity as market vendors, for which, plaintiffs should be made to pay moral damages of not less than P50,000.00 for each defendant;

PRAYER WHEREFORE, it is respectfully prayed that the case be DISMISSED for LACK OF JURISDICTION, and that judgment renders on the counterclaim ordering the plaintiff to pay the following sums, to wit:
1. P50,000 as attorneys fee plus P4,000 as appearance fee per hearing.

2. P20,000 as exemplary damages.

3. P50,000 for the defendant as moral damages. Other equitable remedies applicable are likewise prayed for. Respectfully submitted. Iligan City, August 12, 2011.

ATTY.FARSANA UMPA AMPASO Counsel for the Defendant


Until December 31, 2012 PTR NO. 1234567-01/04/2012 IBP LIFETIME NO.12345 ROLL NO.23456 MCLE CERT.NO.11-0011251-08/21/07 ILIGAN CITY, LANAO DEL NORTE

VERIFICATION AND CERTIFICATION

REPUBLIC OF THE PHILIPPINES CITY OF ILIGAN I, Pedro Skywalker of legal age, single and resident of Tambo, Iligan City, after first being sworn according to law, depose and say that:
1. I am the defendant in the above-entitled complaint;

2. I have caused the preparation and filing of the herein answer;

3. I have read and do understand the contents thereof; 4. I have found every allegation set forth therein as true and correct of our own personal knowledge. I further sayeth naught. IN WITNESS WHEREOF, I have hereto affixed my signature this 12th day of august 2011, in Iligan City.

Pedro Skywalker AFFIANT SUBSCRIBED AND SWORN to before me at Iligan City on this 12th day of August, 2011, the affiant exhibiting his community tax certificates.

Doc. No. 510 Page No.102 Book No.LIX Series of 2011

ATTY.FARSANA U. AMPASO NOTARY PUBLIC


Until December 31, 2012 PTR NO. 1234567-01/04/2012 IBP LIFETIME NO.12345 ROLL NO.23456 MCLE CERT.NO.11-0011251-08/21/07 ILIGAN CITY, LANAO DEL NORTE