Answer To Complaint

Republic of the Philippines
MUNICIPAL TRIAL COURTS IN CITIES

Branch _________
CJ Ramon Q. Avanceña Hall of Justice
Bonifacio Drive, Iloilo City
DINA N. NATUTO
Plaintiff, Civil Case No._______
- versus – For: Sum of Money
with damages
MANDA R. RAMBONG
Defendant
x----------------x
ANSWER WITH COUNTERCLAIM
Defendant, through the undersigned counsel, most

respectfully file her Answer in response to the Complaint of
the Plaintiff and interpose as well as her counterclaim against
the latter, to wit:
Admissions and Denials
1. That the personal circumstances of the plaintiff and the

herein defendant as alleged in Paragraphs 1 and 2 are
admitted;
2. Paragraphs 3 and 5 are admitted;
3. Paragraph 4 is denied insofar as it alleges that the

Defendant has made only the first three months of payments
and failed to pay thereafter and that the defendant has
continuously and intentionally failed to pay her account to the
plaintiff, in the amount of TWO HUNDRED SIXTY
THOUSAND FOUR HUNDRED PESOS and 00/100,
Philippine Currency, (Php260,400.00) as stated therein, the
truth being alleged in the special and affirmative defenses part
herein below.
Special and Affirmative Defenses
1
4. Last May 2, 2016 Defendant paid an amount of SEVENTY
FOUR THOUSAND FOUR HUNDRED PESOS and 00/100,
Philippine currency (Php74, 400.00) representing payment for
six monthly installment of the loan and evidenced by a
payment receipt signed by the plaintiff’s cashier Asi S. Tant.
Machine-copy of the payment receipt is hereby attached as
Annex “A”;
5. On July 10, 2016 the Defendant delivered to the plaintiff’s

car repair shop located at Brgy. Ingore La Paz, Iloilo City, car
accessories and parts valued at ONE HUNDRED NINETY
THOUSAND and 00/100, Philippine currency (Php190,
000.00) and the Plaintiff’s employee, Mika N. Iko signed the
delivery receipt thereof. As agreed by the Defendant and the
Plaintiff the value of the car accessories and parts will serve as
the payment to the Plaintiff of the loan balance amounting to
ONE HUNDRED EIGHTYSIX THOUSAND and 00/100,
Philippine currency (Php186, 000.00). Machine-copy of the
delivery receipt is hereby attached as Annex “B”;
6. That the loan obligation of the Defendant was already

extinguished as early as July 10, 2016. Article 1232 of the
New Civil Code provides that payment means not only the
delivery of money but also the performance, in any manner, of
an obligation. Dation in payment, as in the present case, is a
mode of extinguishment of obligation whereby property is
alienated to the creditor in satisfaction of a debt in money.
Counterclaim
7. Herein defendant incorporates by way of reference all the

foregoing allegations material hereto and by way of
counterclaim hereby further state:
8. Due to the malicious filing of this instant suit, Defendant

have hired the services of the undersigned counsel for an
agreed amount of Philippine Pesos: Fifty Thousand (PHP
50,000.00).
9. That herein defendant is entitled to moral damages in an

amount within the sound discretion of the Honorable Court;
and
2
10. That plaintiff should also be made to pay exemplary
damages to the herein defendant in an amount within the
sound discretion of the Honorable Court.
Prayers
WHEREFORE, it is most respectfully prayed of this

Honorable Court that the case be DISMISSED and that:
A. To pay the herein defendant moral damages in an

amount within the sound discretion of the Honorable
Court;
B. To pay the herein defendant exemplary damages in an

amount within the sound discretion of the Honorable
Court;
C. Plaintiff be ordered to pay all the costs of the suit.
Herein Defendant further prays for such other remedies

just and proper under the premises.
RESPECTFULLY SUBMITTED.
Iloilo City, Philippines, February 17, 2021
RICO IAN P. BLANCO

Counsel for Defendant
196 General Luna Street
Jaro, Iloilo City
PTR No. 6266589/ 1-5-2021
IBP Rcpt. No. 2365900/ 1-5-2021
All Issued at Iloilo City
Roll No. 554789
MCLE Compliance No. V-10169958
Issued on January 15, 2020
At Pasig City, Philippines
VERIFICATION
REPUBLIC OF THE PHILIPPINES)

CITY OF ILOILO ) S.S.
x-----------------------------------------x
3
I, MANDA R. RAMBONG, of legal age, Filipino, married
and resident of Guzman St., Passi City, Iloilo, Philippines,
after being sworn in accordance with law, depose and say that:
I am the defendant in the above-captioned case;
That I have caused to be prepared the above “Answer”

which I have read and understood;
That the allegations thereon are true of my own

knowledge and ability and based on authentic records and
genuine documents.
Iloilo City, Philippines, this 17 th day of February, 2021.
MANDA R. RAMBONG
Defendant
SUBSCRIBED AND SWORN to before me this 17th day of

February 2021 in Iloilo City, Philippines, affiant exhibited to
me her Unified Multi-Purpose ID No. CRN-001-4563-0365-9
issued in Iloilo City, Philippines.
VINCENT T. ALEJANO
Notary Public
For the Province/City of Iloilo
Until December 31, 2021
Commission Register No. 55
Iloilo City, May 15, 2020
299 Desamparados Street,
Jaro, Iloilo City
PTR No. 112256/ 1-5-2021
IBP Rcpt. No. 2525269/ 1-5-2021
Doc. No. 45; All Issued at Iloilo City
Page No. 10; Roll No. 345896
Book No. XXV MCLE Compliance No. V-01236547
Series of 2020 Issued on January 15, 2020
At Pasig City, Philippines

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Republic of the Philippines

MUNICIPAL TRIAL COURTS IN CITIES

ANSWER WITH COUNTERCLAIM

Defendant, through the undersigned counsel, most

Admissions and Denials

1. That the personal circumstances of the plaintiff and the

2. Paragraphs 3 and 5 are admitted;

3. Paragraph 4 is denied insofar as it alleges that the

Special and Affirmative Defenses

5. On July 10, 2016 the Defendant delivered to the plaintiff’s

6. That the loan obligation of the Defendant was already

7. Herein defendant incorporates by way of reference all the

8. Due to the malicious filing of this instant suit, Defendant

9. That herein defendant is entitled to moral damages in an

WHEREFORE, it is most respectfully prayed of this

A. To pay the herein defendant moral damages in an

B. To pay the herein defendant exemplary damages in an

C. Plaintiff be ordered to pay all the costs of the suit.

Herein Defendant further prays for such other remedies

Iloilo City, Philippines, February 17, 2021

RICO IAN P. BLANCO

REPUBLIC OF THE PHILIPPINES)

I am the defendant in the above-captioned case;

That I have caused to be prepared the above “Answer”

That the allegations thereon are true of my own

Iloilo City, Philippines, this 17 th day of February, 2021.

SUBSCRIBED AND SWORN to before me this 17th day of

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