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    of 4

    Republic of the Philippines

    REGIONAL TRIAL COURT


    SEVENTH (7TH) JUDICIAL REGION
    BRANCH 28
    MANDAUE CITY

    RIGOR DIMAGUIBA
    Plaintiff,
    CIVIL CASE NO. 4321

    -versus- FOR: COLLECTION SUM OF


    MONEY

    HESUS NAZARENO MONTENEGRO


    Defendant,

    x-----------------------------------------x

    ANSWER

    COMES NOW, the defendant, by the undersigned counsel unto


    this Honorable Court, and in answer to plaintiff’s complaints,
    respectfully alleges:

    1. That the defendant admits the averment in paragraph 1, 2, and 3


    of the complaint:

    2. That the defendant specifically denies the allegation in


    paragraph of the complaint.

    3. That the defendant has no knowledge or information to form a


    belief as to the truth of the averment in paragraphs 5, 6 and 7 of
    the complaint;

    By way of special and affirmative defenses, defendant avers:

    1. That the obligation has been paid;

    2. That the defendant had purchased said land from plaintiff and
    paid said promissory notes.

    3. That the cause of action has prescribed.

    By way of counterclaim, defendant alleges:

    1. By reason of abuse of a right committed by the plaintiff and by


    reason of the instant precipitate and unfounded suit, the
    defendant was constrained to hire the services of a lawyer to
    defend her rights and interest for a professional fee of eighty
    thousand pesos (P 80,000.00)

    2. Similarly, the plaintiff’s unfounded suit had caused the defendant


    mental anguish, wounded feelings, sleepless nights, serious
    anxieties, and other similar suffering for which the defendant
    claims moral damages of one hundred fifty thousand pesos
    (P150, 000.00)

    PRAYER

    WHEREFORE, it is respectfully prayed to this Honorable Court


    the dismissal of the complaint for lack of merit with cost against the
    plaintiff; and that the defendant’s counterclaim be granted, i.e moral
    damages of one hundred thousand pesos (P 150,000.00), attorney’s
    fees of one eighty thousand pesos (P 80,000.00).

    Other relief and remedies deemed just and equitable under the
    foregoing premises are likewise prayed for.

    Mandaue City, November 18, 2024.

    ATTY. RICARDO DALISAY


    Counsel for the Defendant
    ABC Bldg., A.C Cortes, Mandaue City, Cebu
    Roll No.: 12345
    PTR No.:11223344 01-30-2024, Mandaue City
    IBP No.: 1356789 -01-30-2024, Mandaue City
    MCLE Compliance No.: 9876543 03-24-2024

    VERIFICATION AND CERTIFICATION


    I, HESUS NAZARENO MONTENEGRO, of legal age, after having
    been duly sworn in accordance with law, dispose and say that:

    1. I am the defendant in the above captioned case; I have


    caused the preparation of the foregoing answer;

    2. I have read the allegations contained therein; and

    3. I certify that they are all true and correct of my personal


    knowledge or based on authentic records.

    IN WITNESS WHEREOF, I have hereunto set my hands this 18 th


    day of November at Mandaue City, Philippines.

    HESUS NAZRENO MONTENEGRO


    Affiant
    PRC No. 45678

    SUBSCRIBED AND SWORN TO before me this 18th day of


    November 2024 in Mandaue City, Philippines, affiant exhibiting to me
    her PRC license ID No. 45678 issued in Mandaue City on January 31,
    2023 and valid until January 31, 2026.

    ATTY. RICARDO DALISAY


    Counsel for the Defendant
    ABC Bldg., A.C Cortes, Mandaue City, Cebu
    Roll No.: 12345
    PTR No.:11223344 01-30-2024, Mandaue City
    IBP No.: 1356789 -01-30-2024, Mandaue City
    MCLE Compliance No.: 9876543 03-24-2024

    Doc. No.: 01234


    Page No.: 3
    Book No.: 16
    Series of 2024

    Copy furnished:

    ATTY. MIGUEL LEGASPI


    Counsel for the Plaintiff
    XYZ Bldg., Subangdaku, Mandaue City, Cebu
    Roll No.: 45678
    PTR No.:124578 01-30-2024, Mandaue City
    IBP No.: 142345 01-30-2024, Mandaue City
    MCLE Compliance No.: 9876543 03-24-2024

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