Republic of the Philippine

REGIONAL TRIAL COURT First Judicial Region

Branch 36, Bontoc,
"""""""""""""""""" """""""""""""""""""", Plaintiffs,

ountain Pro!ince

CI#IL CA$E NO% """""""""""""""" (or) RECO#ER* O( PO$$E$$ION AN+ +A AGE$

&!er'u'& """""""""""""""""""""""""""""""""""""" """""""""""""""""""""""""""""""""""""""

Defendants. x-- - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x

ANSWER
,IT- ALL +UE RE$PECT% CO E NO,, the defendants, by the undersigned counsel, and unto this Honorable Court, most respectfully state; 1. The personal circumstances of the parties as set forth in paragraphs 1 and 2 are admitted. There is a need howe er to drop the names of parties who ha e no interest or participation whatsoe er in this action so that the actual merits of the contro ersy may be speedily determined. The following defendants who do not stand to be benefited or in!ured by the !udgment in this suit are not real parties-in-interest, hence, their names should be dropped" #ps. C$%CH&T' '('%$# '%) C$%CH&T$ '('%$# ('%&'%' ('*&+$T '%) (',&%$ ('*&+$T The affida it declaring the non-interest and non-participation of the abo e-named defendants is hereto attached as 'nnex 1 hereof; 2. The real party-in-interest in the abo e-entitled case who claim ownership o er the property in suit are the spouses +.(/'#' 0'01T '%) /'/1%' 0'01T. Their children who are li2ewise impleaded in the complaint may li2ewise be dropped since the !udgment will be binding to them;

3. The allegations in paragraphs 3, 4 and 5 including the genuineness and authenticity of the documents referred to therein are specifically denied for want of 2nowledge sufficient to form a belief as to the truth thereof. The truth of the matter are those set forth in the affirmati e defenses as will be expounded hereunder; 4. 6aragraphs 7, 8, 9 and : including those set forth in paragraphs 1;,11,12,13 and 14 are ehemently and strongly denied for want of 2nowledge sufficient to form belief as to the truth thereof, the truth being those set forth in the affirmati e defense; )efendants hasten to add that the demand to acate has no factual and legal bases and the claims for damages ha e no bases in fact and in law. &f e er plaintiffs suffered damages they only ha e themsel es to blame for instituting a baseless suit;

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5. The Tax )eclaration of plaintiffs upon which they anchor their possessory rights and interest do not co er the property in suit. The property in suit is separate and distinct from the property embraced under plaintiff>s tax declaration; 7. The property in suit had been materially possessed and occupied by the predecessor-in-interest of defendants +.(/'#' 0'01T '%) /'/1%' 0'01T since time immemorial as demonstrated by the substantial impro ements they ha e introduced on the property such as but not limited to the following" two ?2@ fishponds, old fences enclosing the wide expanse of the property; a semi bungalow house and a granary where rice and corn are stored during har est season, the con ersion of substantial portion of the pastureland into an arable land suitable for agricultural production, fruit bearing bananas and coconuts, and the declaration of the property for taxation purposes as early as in 1:83 and the religious payment of taxes due the go ernment, among others; The Tax )eclaration of ('*'/&T'+, father of defendant +.(/'#' 0'01T is hereto attached as 'nnex 2 hereof;

PRAYER
,-ERE(ORE, premises duly considered, it is most respectfully prayed of this Honorable Court to issue !udgment in fa or of the defendants as follows" 1. To dismiss the instant case for lac2 of merit;

2.

To declare defendants as the lawful owners and possessors of the property in suit;

This 29th day Aune, 2;1; at /ontoc, (ountain 6ro ince.

______________
Counsel for the Defendants

Bontoc, Mountain Province

,oll %o. BBBBBBBBBBBBBBBBB 6T,. %o. BBBBBBBBBBBBBBBBBBB (C*1 Compliance %o. &&BBBBBBBBBBBBBB (C*1 Compliance %o. BBBBBBBBBBBBBB The Cler2 of Court ,TC-/ranch 37 Creetings. .pon receipt hereof, please submit the foregoing for the 2ind consideration of the Honorable Court.

""""""""""""""""" Counsel for the Plaintiffs