REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
MAKATI CITY

PLAINTIFF

CIVIL CASE NO. 14-327

-versus-

REVOCATION OF DEED OF DONATION

DEFENDANT
x-----------------------------------X
ANSWER WITH
COMPULSORY COUNTERCLAIMS
TO THE
COMPLAINT DATED MARCH 21, 2014
Defendant, through counsel, most respectfully submits this ANSWER WITH
COMPULSORY COUNTERCLAIMS TO THE COMPLAINT DATED MARCH 21, 2014 received on April
1, 2014, she alleges, that:

BY WAY OF ANSWER
A. To The Personal Circumstances
1. Defendant ADMITS the allegation in Number 1 of the COMPLAINT;
2. She admits residing at 25 Urdaneta Avenue, Urdaneta Village, Makati City, but
SPECIFICALLY DENIES the allegations as to a residence at Bella Villa Condominiums, 5
Hamburg Street, MErville Subdivision, Paranaque City, as alleged in Number 2 of the
Complaint, Defendants residence remains at the Urdaneta Home;
3. She ADMITS the allegations in Number 3 of the COMPLAINT;
B. To The Bases of the COMPLAINT Dated March 21, 2014

4. Defendant ADMITS the execution of the Deed of Donation, Annex A, COMPLAINT,

and the acceptance thereof on her behalf by her mother, as stated in Number 4 of the
COMPLAINT;
4.1 She ADMITS further the consideration in the Deed of Donation that: For and in
consideration of the love and affection (Not great love and affection, as stated in
Number 4 of the COMPLAINT) which the DONOR (the plaintiff) has for the DONEE
(the defendant) x x x, and adds paragraph 3 of the Deed of Donation, Annex A,
COMPLAINT, that: The DONEE hereby accepts the donation of the above-described
personal properties and does hereby expresses (sic) her gratitude for the kindness
and liberality of the DONOR
5. The statements in Number 5 of the COMPLAINT are not statement of the ultimate
facts on which the party pleading relies on for his claims, Rule 8, Section 1, the 1997 Rules of
Civil Procedure, but are the plaintiffs conclusions on the defendants conduct defendant
started to exhibit hostility and hatred towards him or the plaintiffs own thinking about his, the
plaintiffs motivations This was despite plaintiffs unwavering love, sincere care, and
consistent support for her welfare and well-being;
5.1 Nonetheless, these conclusions will be addressed by the Defendant subsequently in
the succeeding portions of this ANSWER WITH COMPULSORY COUNTERCLAIMS;
6. Defendant ADMITS throwing a glass at the direction of the plaintiff, ADMITS not
apologizing therefore, and finally ADMITS not talking to the plaintiff since she and her mother
returned to Manila from abroad in May 2009, while her father continued his vacation therein,
as alleged in Number 6 of the COMPLAINT, but SPECIFICALLY DENIES the rest of the allegations
and conclusions therein, the truth of the matter being that, as stated in the defendants
allegedly scathing letter,
x x x. This same fight I mention here is one and the same with that mentioned in your
letter referencing to when I threw the glass in our Vancouver kitchen in your direction
while being forced to listen to the exchange of anger down the hall. As someone who
has thrown around plates, trays, other glasses, silverwares, newspapers, remote
controls, hurtful words, and banged tabletops in bouts of anger and frustration himself,
I expected you to realize that that was my response to overwhelming anger I was feeling
towards the situation then. In the same instance you tried to hit my face with my laptop,
But did not do so, instead slammed it into the floor. X x x
7. She ADMITS seeing her plaintiff-father at the Manila Cathedral and turning away
from him, as alleged in Number 6 of the COMPLAINT, but this happened in June 24, 2010, not
August 2009; she specifically DENIES the rest of the allegations and conclusions therein, the
truth of the matter is ascan clearly be gleaned on the defendants allegedly scathing letter,

x x x. I was next in line for the comfort room when you walked by and felt a slight
touch on my elbow, only to turn around to see a person I hadnt spoken to in a couple of
years, a person who threatened to slam my face with a laptop. X x x. You would forgive
me if I wasnt to keen on showering my affection on a person whose memories I have
about consist of those things.
8. Defendant has no knowledge or information as to the truth of the term paper
written of in the first paragraph Number 8 of the COMPLAINT; she adds however, that, as
stated in said defendants scathing letter, also:
To address another point made, I really dont know what term paper you are referring
to in your letter, that which you say contains statements blatantly displaying how much
I hate you. X x x. I dont find a need to publicize, and what more exaggerate, parentchild problems to individuals who have nothing to do with the situation so I dont
understand how you can claim this.
8.1 She has no knowledge or information as to the truth of the allegations and ending
conclusion expressed in the second paragraph of Number 8;
9. As to the Number 9 of the COMPLAINT, she ADMITS the filing of Case No. 12-338,
for cancellation of adverse claim and recovery of damages, Regional Trial Court, Makati City,
Branch 150, subsequent to the annotation, by the plaintiff, of an adverse claim on the property
located at 25 Urdaneta Avenue, Urdaneta Village, covered by TCT No. 198462 of the Registry of
Deed of Makati City in the name of the Defendants mother and defendant, but specifically
DENIES these statements therein xxx defendant added insult to the injury she had already
caused plaintiff and This suit was done with sinister motives or ill-will, as these statements
are conclusions not ultimate facts;
9.1 To explain this corollary issue, so goes the beginning of paragraph 2, Number 9
COMPLAINT, and the succeeding paragraphs, should be done in the RTC 148 and 150
of Makati City, not in this Court;
9.2 In Number 9, Complaint, the plaintiff painted an incomplete picture of the
controversy by including only Civil Case No. 12-338 of RTC 150, Makati City, to
complete the picture, to view the controversy in its entirety and to give the proper
context to the filing of this case, the defendant lists down the cases between
husband against wife, husband/father against wife and daughter, wife and daughter
against husband/father, and father against daughter, as the case herein;
The proper context therefore, is not to view this case only in connection with Civil
Case No. 12-338, as Number 9, Complaint does, but to view the set of nine (9) cases involving
the parties;

10. She ADMITS her graduation from the De La Salle University in 2013, this being
alleged in Number 10 of the COMPLAINT, but she has no knowledge or information as to the
truth of the rest of the allegations and conclusions therein;
11. Of all the statements in Number 11 of the COMPLAINT, she, the defendant
ADMITS only the writing of July 9, 2013 letter, the payment by the plaintiff of the defendants
tutition fees, and the P88,000.00 monthly allowance, she, the defendant has no knowledge or
information as to the truth of the other allegations and conclusions therein, It is every fathers
responsibility to provide for his child. If parents expected reimbursement for every good thing
they did for their children, then kids might as well move out and live on their own the moment
they transition from crawling to walking to avoid incurring debt;
12. Defendant ADMITS Article 765 of the Civil Code, as reproduced in Number 12 of
the COMPLAINT;
13. The sentence in Number 13, COMPLAINT, that Here, defendant committed a
series of acts that constitute an offense against the person, honor, or property of the plaintiff
is a conclusion, which is nonetheless SPECIFICALLY DENIED;
14.