Republic of the Philippines

Municipal Trial Court

First Judicial Region
Baguio City
Branch _____

Juan Go,
Plaintiff,
- Versus

Civil Case No.________

For: Collection of Sum of Money
-

Juana Sy,
Defendant.
x-------------------x
ANSWER
COMES NOW the defendant through the undersigned counsel, by
way of answer to the plaintiffs consent, hereby respectfully alleges that:
1. She admits the allegations in paragraph 2 of the complaint
regarding her personal circumstances;
2. She is without knowledge or information to form a belief as to the
truth of the allegations in paragraphs 1, 4, 6, 8 and 9 of the
complaint;
3. She denies the material allegations in paragraph 3 in the complaint,
since such allegations are meant to unjustly enrich the Plaintiff at
the Defendants expense. The truth to the matter is that the
principal obligation of the defendant only amounts to three
hundred thousand Philippine pesos (P300,000.00) as where the
defendant has agreed to. But due to an unconscionable and
enslaving monthly interest of 12% defendant later on learned that
she was deceived into signing the agreement and that she is forced
to pay an obligation of an aggregate amount of indebtedness
amounting to One Million one hundred sixty four thousand
Philippine pesos (P1,164,000.00), exclusive of other charges;
4. She denies that there was a valid demand to pay stated in
paragraph 7 of the complaint that the demand to pay her obligation
was made on the 13th of February 2015, hence no formal demand
has been made;
5. Plaintiffs complaint does not state a cause of action;

6. She admits that sometime on the 14th of February 2015, defendant

incurred and indebtedness of Three Hundred Thousand Philippine
Pesos (P300,000.00) with Plaintiff;
7. Due to the long relationship of Plaintiff and Defendant as
neighbors, Defendant was deceived into signing a promissory note
which she thought contained only a reasonable interest rate per
Defendants and Plaintiffs prior oral agreement;
8. Upon further review of the Promissory Note which she received
later, Defendant discovered with sheer surprise that the interest rate
on the receipt is at Twelve percent (12%) monthly and not annually
as to their oral agreement;
WHEREFORE, it is respectfully prayed that the Plaintiffs complaint
be dismissed with costs against the Plaintiff. The Defendant further prays for
such other relief as the Honorable Court may deem just and equitable.
Baguio City, June 15, 2015.
ATTY. CHENELYN N. BARBAR
Counsel for the Defendant
#7 Harrison Road, Baguio City
Roll No. 570522 IBP No.600488 MCLE Compliance No. 14-00069924

VERIFICATION AND CERTIFICATION

I, Juana Sy, of legal age, Filipino, single and a resident of #2 Harrison
Road, Baguio City, after having been duly sworn in accordance with law
hereby state that:
1. I am the defendant in the above entitle case; that I have caused the
preparation of the foregoing Answer Pleading; and that all the
allegations stated herein are true and correct of my own knowledge
and supported by authentic documents;
2. That I have not commenced any other action or proceeding
involving the same parties or issues in any other honorable court or
tribunal; that to the best of my knowledge no such action or
proceeding involving the same matter is pending or has been
terminated in any other honorable court or tribunal; and that I

undertake to duly report that fact upon knowledge within five (5)
days therefrom to this Honorable Court.
Juana Sy
Affiant
SUBSCRIBED AND SWORN to before me this 15th of June 2015 at
Baguio City after exhibiting to me her Drivers License with DL No. A01456-131511 issued in Baguio City on December 12, 2014.

Doc No: ____

Page No. :___
Book No.:___
Series of 2015

ATTY. CHENELYN N. BARBAR

Notary Public for and in the City of Baguio
Until December 31, 2015
#7 Harrison Road, Baguio City
Roll No. 570522
IBP No.600488
MCLE Compliance No. 14-00069924