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Defendant's Answer in Civil Case 1376

This document is an answer filed by the defendant Johannes Muncal in response to a civil complaint filed against him by Barack Obama. In the answer, Muncal admits some allegations in the complaint but denies others, specifically denying paragraph 4. Muncal also claims lack of knowledge regarding other allegations. Muncal asserts special defenses including payment, purchase of land, and prescription. Muncal files a counterclaim seeking damages of 10,000 pesos for costs incurred due to the plaintiff's "unwarranted and malicious act." The answer requests dismissal of the complaint and an award of 5,000 pesos in damages.

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204 views3 pages

Defendant's Answer in Civil Case 1376

This document is an answer filed by the defendant Johannes Muncal in response to a civil complaint filed against him by Barack Obama. In the answer, Muncal admits some allegations in the complaint but denies others, specifically denying paragraph 4. Muncal also claims lack of knowledge regarding other allegations. Muncal asserts special defenses including payment, purchase of land, and prescription. Muncal files a counterclaim seeking damages of 10,000 pesos for costs incurred due to the plaintiff's "unwarranted and malicious act." The answer requests dismissal of the complaint and an award of 5,000 pesos in damages.

Uploaded by

John Michael Babas
Copyright
© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines REGIONAL TRIAL COURT Second Judicial Region Branch __ Cauayan City, Isabela -oOo-

BARACK OBAMA, Plaintiff, CIVIL CASE No. 1376 -versus-

JOHANNES MUNCAL, Defendant, x-----------------------------------x ANSWER NOW COMES the defendant in the above entitled case, and to this Honorable Court most respectfully alleges:

1. 2.

Defendant admits the averment in paragraph 1, 2 and 3 of the complaint; Defendant specifically denies the allegation in paragraph 4 of the complaint, the truth being that. ( State here the fact being claimed by the defendant as the true state of facts or the truth being those stated in the special and affirmative defenses herein set forth)

3.

Defendant has no knowledge or information to form a belief as to the truth of the averment in paragraphs 5,6,7 and 8 of the complaint;

By way of special and affirmative defenses, defendant avers: 1. 2. That the obligation has been paid; That the defendant had purchases said land from plaintiff and paid said promissory notes; 3. That the cause of action has prescribed.

By way of counterclaim, defendant alleges: 1. That by virtue of this unwarranted and malicious act initiated by the plaintiff, defendant was forced to engage services of counsel in the sum of P10, 000.00.

PRAYER WHEREFORE, it is respectfully prayed that the complaint be dismissed and defendant be awarded the amount of P5, 000.00 Other equitable reliefs are likewise prayed for.

Cauayan City, for Alicia, Isabela, August 25, 2013.

PUBLIC LAWYERS OFFICE Cauayan District Cauayan City, Isabela BY: PING GUERRERO Counsel for Defendants Roll No. 57612 February 31, 1969 PTR. No. 4919904 - 5/5/05

VERIFICATION

I, JOHANNES MUNCAL, of legal age, Filipino and from Cauayan City, Isabela, after being duly sworn to in accordance with law, hereby depose and say:

That I am the defendant in the above-entitled case; That I caused the preparation of the foregoing Answer; That the contents therein are true and correct to the best of my knowledge.

IN WITNESS THEREOF, I have hereunto affixed my signature this ___ day of ____ 2013, at Cauayan City, Isabela.

JOHANNES MUNCAL Defendant

SUBSCRIBED AND SWORN to before me of even date at the same place.

DOC. NO. ______ PAGE NO. _____ BOOK NO. _____ SERIES OF 2013.

COPY FURNISHED BY REG. MAIL: ATTY. KEN DY Rizal Avenue, District II Cauayan City, Isabela

EXPLANATION A copy of this Answer was served to plaintiffs counsel by registered mail and lack of personnel of PAO to personally serve the same.

PING GUERRERO

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