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Answer LOLITA SY

1) The defendant filed an answer to the plaintiff's complaint for collection of money. 2) The defendant admits some facts alleged in the complaint but denies being in default of payment for the month of December 2017, providing a payment receipt as evidence that the amount was paid. 3) The defendant denies the validity of the amount claimed and that the demand for payment is premature, requesting that the complaint be dismissed.

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132 views2 pages

Answer LOLITA SY

1) The defendant filed an answer to the plaintiff's complaint for collection of money. 2) The defendant admits some facts alleged in the complaint but denies being in default of payment for the month of December 2017, providing a payment receipt as evidence that the amount was paid. 3) The defendant denies the validity of the amount claimed and that the demand for payment is premature, requesting that the complaint be dismissed.

Uploaded by

Jo BD
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Republic of the Philippines

National Capital Judicial Region


RTC, Branch 123
Caloocan City

JOY SALVA
Plaintiff,

-versus- Civil Case No. 12345


For: Collection of sum of
money

LOLITA SY
Defendant.
x-------------------------x
ANSWER

Defendant, through counsel, and in the answer to the Plaintiff’s complaint, states that:

1. Defendant admits Paragraphs 1, 2, 3 and 4 of the Complaint;

2. Defendant specifically denies the material allegations in paragraph 5 of the complaint, and
that, in truth and in fact, the Defendant already paid One Hundred Thirty Thousand Pesos
(P130,000.00) representing his monthly obligation for the month of December as
evidenced by Payment Receipt executed by the Plaintiff. A copy of the receipt is herein
attached as annexed “1”.

3. Plaintiff’s allegation on the same paragraph as mentioned above that the amount of Five
Hundred Twenty Thousand (P520,000.00) is due and demandable because of a default in
payment for the month of December 2017 is therefore without any legal ground.

4. Defendant categorically denies having received any Demand Letter/Letters from the
Plaintiff.

5. Defendant submits that the Complaint has no cause of action as the amount of the balance
demanded by the Plaintiff is not yet due and demandable.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court


that the Complaint filed be dismissed.

The Defendant likewise prays for such other remedies and reliefs as may be deemed just
and equitable under the premises.
09 February 2018. Caloocan City, Philippines.

ATTY. JOSE P. RIZAL


Counsel for the Defendant
101 XXX St., Caloocan City
(02) 444-000
Roll of Attorney No. 10101
IBP No. 4080255 / June 2014. Caloocan City.
PTR No. 9833997 / June 2014. Caloocan City.
MCLE Certificate of Compliance No. 14344

EXPLANATION

A copy of the foregoing Answer was served to the Plaintiff’s counsel by registered mail due to
time and distance constraints and for lack of manpower who can serve the same in person.

ATTY. JOSE P. RIZAL


Counsel for the Defendant

Cc:
ATTY. JUAN DELA CRUZ
Counsel for the Plaintiff
No. 123 ABC St., Caloocan City

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