REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT OF MANILA
MANILA, BRANCH 2

JUAN CRUZ,
Plaintiff;
Civil Case No. 07-123456
--- versus ---FOR:

SUM

OF

MONEY

AND
DAMAGES
JOHN REYES,
Defendant.
x---------------------x
ANSWER AD CAUTELAM
COMES NOW the defendant by the undersigned counsel and
in answer to plaintiffs complaint, respectfully avers;
1. That he admits paragraphs 1 and 2 of the complaint;
2. That he is without knowledge or information to form a belief
as to
the truth of the averments made in paragraph 4 thereof;
3. That he DENIES specifically each and every material
allegation in
paragraphs 3, 5 and 6 of the complaint; and alleges that on March 1,
2012,the defendant went to the residence of the plaintiff to borrow a
sum of money amounting to P600,000.00. The plaintiff went to his
room and upon his return to the sala, he gave a white envelope to the
defendant containing P600,000.00. The plaintiff told the defendant
that he will be leaving for Los Angeles, California, USA, on March 3,
2012 and will be staying there until June 1, 2012. In this regard, the
plaintiff told the defendant that he could pay his debt after June 1,
2012 or when he returns in the Philippines. However, defendant told
plaintiff that he will be paying his debt on March 15, 2012 as he will
be receiving payment of the same amount from his debtor on that
day. The plaintiff agreed and told the defendant that he could pay the
loaned amount to the plaintiffs wife, Carla Cruz. Thereafter, the
defendant executed a promissory note (attached as Annex 1) in
favor of the plaintiff in the amount of P600,000.00 payable on or
before March 15, 2012 which reads as follows:
I, promise to pay Juan Cruz the sum of 600,000.00
on or before March 15, 2012.

III.7.F-1

John Reyes 3/1/2012

III.7.F-1

4. The defendant reserves the right to file a motion to dismiss

for
lack of jurisdiction.
WHEREFORE, it is respectfully prayed that
(a)Judgment shall be rendered in favor of the defendant with
respect
to the plaintiffs complaint;
(b)That the defendant reserves the right to file a motion to
dismiss
for lack of jurisdiction.
(c) For such other relief consistent with law and equity and for
costs.
Manila, Philippines, April 5, 2012.

Karlo Reyes
Counsel for Defendant
th
25 Floor PS Bldg.Taft, Manila
PTR No. 135790/Manila/1/10/2008
IBP No. 135790/Manila/1/20/2008
Roll of Attorneys No. 654321
MCLE Compliance No.
111111 1/3/2012
Tel No. 6561997

VERIFICATION
I, John Reyes, of legal age, subscribing under oath, hereby depose
and state that:
1. I am the defendant in the above-entitled case, and that I
have
caused for the preparation of the foregoing Answer ;
2. I have read the foregoing answer and the allegations therein
are true and correct based on my own personal knowledge;
3. I attest to the authenticity and due execution of the annex
thereto.
John Reyes
III.7.F-2

Defendant

III.7.F-2

SUBSCRIBED and SWORN to before me this 5 th day of April

2012, in Taft, Manila. The affiant exhibiting to me his SSS No. N2601-11111 issued by Social Security System, on April 12, 2001 and
Drivers License No. 87654321 issued on November 1, 2010 at Taft,
Manila.

Atty. Don De Leon

Notary Public for Manila
#45 Burgos St., Taft, Manila
Roll of Attorneys No. 12345
PTR No. 123456 01/10/08
IBP No. 56789123 01/28/02
MCLE Compliance No. 1-002746
1/3/2012

Doc. No. 1
Page No. 2
Book No. 3
Series of 2011

Copy Furnished:
Ira Santos
Counsel for Plaintiff
2nd Floor, RC Bldg, Taft Manila
Tel No. 123456
EXPLANATION :
Copy of the foregoing is being served by registered mail to the
plaintiffs address due to distance and lack of personnel.

KARLO REYES

III.7.F-3