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    Answer 3

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    ShynnMiñoza
    This document is an Answer filed by the defendant Maya Pala U. Tang in response to a civil complaint brought by Vangie G. Utangan for collection of money with damages. The defendant admits some allegations of the complaint but denies owing the full amount claimed. The defendant requests that the parties be given time for mediation and, failing that, asks that the complaint be dismissed and a counterclaim for attorney fees and damages be granted.

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    Answer 3

    Uploaded by

    ShynnMiñoza
    67 views4 pages
    This document is an Answer filed by the defendant Maya Pala U. Tang in response to a civil complaint brought by Vangie G. Utangan for collection of money with damages. The defendant admits some allegations of the complaint but denies owing the full amount claimed. The defendant requests that the parties be given time for mediation and, failing that, asks that the complaint be dismissed and a counterclaim for attorney fees and damages be granted.

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    This document is an Answer filed by the defendant Maya Pala U. Tang in response to a civil complaint brought by Vangie G. Utangan for collection of money with damages. The defendant admits some allegations of the complaint but denies owing the full amount claimed. The defendant requests that the parties be given time for mediation and, failing that, asks that the complaint be dismissed and a counterclaim for attorney fees and damages be granted.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    67 views4 pages

    Answer 3

    Uploaded by

    ShynnMiñoza
    This document is an Answer filed by the defendant Maya Pala U. Tang in response to a civil complaint brought by Vangie G. Utangan for collection of money with damages. The defendant admits some allegations of the complaint but denies owing the full amount claimed. The defendant requests that the parties be given time for mediation and, failing that, asks that the complaint be dismissed and a counterclaim for attorney fees and damages be granted.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 4

    Republic of the Philippines

    12th Judicial Region


    REGIONAL TRIAL COURT
    Branch 4
    Iligan City

    VANGIE G. UTANGAN
    Plaintiff, Civil Case No. 2018-092414
    For: Collection of Sum of
    -versus- Money with Damages

    MAYA PALA U. TANG


    Defendant.
    x-------------------------------------------------------x

    ANSWER

    COMES NOW, the Defendant by undersigned Counsel and in answer to


    Plaintiff’s Complaint in the above-entitled case, respectfully allege:
    1. Defendant admits the averment in paragraph(s) 1,2,3,4 and 7.

    2. Defendant specifically deny the allegation paragraph 5 of the Complaint, the


    truth being that, the Defendant with a temporary receipt signed by the Plaintiff,
    said Plaintiff received not just FORTY FIVE THPUSAND PESOS (P45,000.00) as
    partial payment but received as reflected in the temporary receipt the amount of
    ONE HUNDRED FORTY FIVE THOUSAND PESOS (P145,000.00) as partial
    payment.

    3. Defendant has no knowledge or information to form a belief as to the truth


    of the averment in paragraph 6 of the Complaint, as the payment for the remaining
    obligation is not yet overdue up until November 14, 2018 as reflected in the
    “KASABUTAN” made by and between the Plaintiff and the Defendant, hereto
    attached as Annex “A”.

    4. Defendant vehemently denies under oath paragraph 8, the truth being that,
    the Defendant did not acted fraudulently and has no intention to evade her
    obligation with the Plaintiff.

    5. Any allegation not expressly and specifically admitted herein shall be


    generally denied.

    WHEREFORE, premises considered, it is respectfully prayed that the


    parties be given ample time to reach an amicable settlement before the Mediation
    Center, and that in case of a failure thereof, and after trial, the Complaint be

    1
    dismissed for lack of merit and Defendant Compulsory Counterclaim be granted,
    i.e., Attorney fees plus moral damages of P50, 000.00, plus cost of suit.
    The Defendants respectfully pray for such and other reliefs as may be
    deemed just and equitable in the premises.
    Iligan City, 28 September 2018.

    DELIMUD LAW FIRM


    131 Panay Reklamo Avenue, Aguinaldo Building
    1103 Iligan City

    RACQUEL M. DELIMUD
    PTR No. 8438426; 1/04/2007; Iligan City
    IBP No. 568943; 1/04/2007; Iligan City Chapter
    Roll of Attorneys No. 34328

    2
    REPUBLIC OF THE PHILIPPINES )
    CITY OF ILIGAN ) S.S.

    VERIFICATION and CERTIFICATION

    I, MAYA PALA U. TANG, of legal age, Filipino, and a resident of Purok


    Ilang-Ilang, Barangay Villaverde, Iligan City, after having been duly sworn to in
    accordance with law, do hereby depose and state;

    1. That I am the Defendant in the above-entitled case;

    2. That I have caused the preparation of said Answer thru my counsel;

    3. That I hereby certify that I have read and understood all the denials and
    admittance contained therein;

    4. That the contents therein are true and correct to the best of my personal
    knowledge and based on documents in my possession;

    5. That I further certify that there is no other action pending between the
    same parties for the same cause of action and subject matter before the Supreme
    Court, the Court of Appeals, or any other court or tribunal, and we hereby warrant
    that if one is filed, or is known to exists, we will forthwith inform or notify this
    Honorable Court within five (5) days from notice thereof.

    IN WITNESS WHEREOF, I have hereunto set my hand on this ___ day of


    September, 2018 at Iligan City, Philippines.

    MAYA PALA U. TANG


    Affiant

    SUBSCRIBE AND SWORN to before me on ____ day of _________, 2018,


    affiant having exhibited to me his Community tax Certificate No. __________
    Issued on ____________, Issued at ______________.

    Doc No. ____ ATTY. CARLO Z. SUAREZ


    Page No. ____ PTR No. 5431011 – 1/3/18 - Iligan City
    IBP Lifetime No. 010393/Iligan City
    Book No. ____
    Chapter
    Series of 2018. MCLE Compliance No. V-0006521
    Roll of Attorneys No. 8

    3
    4

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