REPUBLIC OF THE PHILIPPINES
REGIONAL TIAL COURT
Eleventh Judicial Region
Branch 15
Davao City
DAVAO RABBIT BUS LINE, CIVIL CASE NO.
323819-11
Plaintiff.
FOR: DAMAGAES
AND ATTORNEY’S
FEES
VERSUS
AMADOR BULAN, ROLANDO
SUIZO and FIRST
INTEGRATED BONDING AND
INSURANCE COMPANY, INC.
Defendants
X------------------------------------------------X
ANSWER
COMES NOW the Defendant AMADOR BULAN, through the
undersigned counsel, and in answer to Plaintiff's complaint,
respectfully alleges:
ADMISSIONS AND DENIALS
1. Defendant admits the averment in paragraph 4, 5, and 7
of the complaint;
1
2. Defendant specifically denies the allegation in paragraphs
9 of the complaint, the truth being that the Traffic accident
Report (Annex B) is silent whether it is the reckless
driving of defendant Rolando Suizo and his disregard of
the traffic rules and regulations that caused the collision.
3. Defendant specifically denies the allegation in paragraph
14, there is no failure to comply with the demand since
the claim of the plaintiff is not grounded on any justifiable
cause of action against the defendant.
SPECIAL AND AFFIRMATIVE DEFENSES
By way of special and affirmative defenses, defendant avers
that:
4. The defendant observed the standard of a good father of
a family in the selection and supervision of its employee
(Annex ____)
5. There is no cause of action against the defendant since
the allegations of the plaintiff fails to specify the basis for
its claim.
6. The plaintiff failed to produce proof as to its alleged loss
of earnings.
COUNTERCLAIM
By way of counterclaim, defendant alleges:
7. That by virtue of this unwarranted and malicious act
initiated by the plaintiff, defendant was forced to engage
counsel in the sum of P10,000.00.
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WHEREFORE, it is respectfully prayed that the complaint be
dismissed and defendant be awarded the amount of P10,000.00
Other equitable reliefs are likewise prayed for.
Davao City, Philippines, February 13, 2019.
Atty. Kahlil Alcomendras
Counsel For Petitioner
rd
3 Foor Black Building, E. Jacinto Street, 8000 Davao City
IBP Lifetime No.1234567; Davao City
PTR No. 145690; January 1, 2019, Davao City
Roll of Attorney No. 9001 MCLE Compliance No. 89172
Atty. Patricia Balgoa
Counsel For Petitioner
rd
3 FloorBlack Building, E. Jacinto Street, 8000 Davao City
IBP Lifetime No.984059; Davao City
PTR No. 2080203; January 1, 2019, Davao City
Roll of Attorney No. 7080901
MCLE Compliance No. 19837
Atty. Stephanie Publico
Counsel For Petitioner
rd
3 Floor Black Building, E. Jacinto Street, 8000 Davao City
IBP Lifetime No.45293; Davao City
PTR No. 10984; January 1, 2019, Davao City
Roll of Attorney No. 1289
MCLE Compliance No. 981394
Atty. Ace Ugdang
Counsel For Petitioner
rd
3 Floor Black Building, E. Jacinto Street, 8000 Davao City
IBP Lifetime No.45019; Davao City
3
PTR No. 109382; January 1, 2019, Davao City
Roll of Attorney No. 8793
MCLE Compliance No. 390941
VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING
I, AMADOR BULAN, of legal age, do hereby state that: I am
the defendant in the complaint entitled COMPLAINT FOR DAMAGES
and in such capacity, caused this counter-complaint to be prepared; I
have read its contents and affirm that they are true and correct to the
best of my own personal knowledge; I hereby certify that there is no
other case commenced or pending before any court involving the
same parties and the same issue and that, should I learn of such a
case, I shall notify the court within five (5) days from my notice.
IN WITNESS WHEREOF, I have signed this instrument on
February 13, 2019.
AMADOR BULAN
SUBSCRIBED AND SWORN TO before me in the City of
Davao on this 13th day of February 2019, affiant exhibiting before me
his identification GSIS Multipurpose ID No. 123-1234-1234-1
Ace R. Ugdang
4
NOTARY PUBLIC
Commission Expires on December 31, 2019
IBP Lifetime No.45019; Davao City
PTR No. 109382; January 1, 2019, Davao City
Roll of Attorney No. 8793
MCLE Compliance No. 390941
Doc. No. 2
Page No. 1
Book No. I
Series of 2019
