REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

BRANCH 2
Makati CITY
Landlord Lando
represented by Maria Lando and his Atty in Fact
Plaintif
Civil Case
No. 1
Unlawful
Detainer
-

Versus

Tenten Falso,
Defendants
x---------------------------------x

The DEFENDANT xxx, by counsel, respectfully states:

ANSWER
1.

Paragraphs 5 and 7 of the Complaint are admitted.

2. Paragraphs 9 of the Complaint are denied for lack of

knowledge or information sufficient to form a belief as to the
veracity or falsity thereof, the allegations therein being matters
known only to, and are within the control only, of the plaintiff.
3. Paragraph 11 of the Complaint is denied for lack of
knowledge and information sufficient to form a belief as to the
veracity or falsity of the alleged amounts of attorneys fees
agreed upon between the plaintiff and her lawyer.

III.

COMPULSORY COUNTERCLAIM

4 .By reason of the abuse of right committed by the plaintiff

and by reason of the instant precipitate and unfounded suit, the
defendant was constrained to hire the services of a lawyer to
defend his rights and interests for a professional fee of
P20,000.00 plus P3,000.00 per court appearance;
5. Similarly, the plaintiffs unfounded suit has caused the
defendant mental anguish and suffering and public humiliation
and embarrassment, for which the defendant claims moral
damages of P100,000.00.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed that
the parties be given ample time to reach an amicable settlement
before the MakatiCity Mediation Center; and that in case of a
failure thereof, and after trial, the complaint be dismissed for lack
of merit and the defendants compulsory counterclaim be
granted, i.e.. attorneys fees of P20,000.00 plus moral damages of
P100,000.00, plus costs of suit.
The defendant respectfully prays for such and other reliefs
as may be deemed just and equitable in the premises.
Makati City, 2016.
ABC LAW OFFICES
Counsel for Defendant
123 Makati CIty
Philamlife Village, Las Pinas City 1740
Don Aba
VERIFICATION
AND

ANTI-FORUM SHOPPINFG CERTIFICATION

I, TenTen Falso, of legal age, married, Filipino, and with
postal address c/o 123, Makati City, under oath, depose:
I am the defendant in the foregoing case; that I caused the
preparation of the foregoing Answer; that I have read its contents;
and that the same are true and correct of my own direct, personal
knowledge.
Further, pursuant to Rule 7 of the 1997 Rules of Civil
Procedure and existing Supreme Court circulars, I hereby certify
that I have not heretofore commenced any other action or
proceeding involving the same issues in the Supreme Court, the
Court of Appeals, or any other tribunal or agency; that to the best
of my knowledge, no such action or proceeding is pending in the
Supreme Court, the Court of Appeals, or any other tribunal or
agency; and that if I should hereafter learn that other similar or
related actions or proceedings has been filed or is pending before
the Supreme Court, the Court of Appeals, or any other tribunal or
agency, I undertake to report that fact within five (5) days
therefrom to this court.

MakatiCity, December 20
2017.
Tenten
Falso
Affiant/Defendant
SSS
Member ID
No. 12356
Issued on
1995

SUBSCRIBED and sworn to before me in xxx City on xxx

2011, the affiant showing his SSS Member ID Card as stated
above as competent proof of his identity.

NOTARY PUBLIC
Doc. No. 1234
Page No. _54123
Book No. 1234
Series of 2011
Cc

Atty. Don Aba

Counsel for Plaintiff
Makati City
Metro Manila

EXPLANATION
A copy of this pleading is served via registered mail,
instead of via personal service, on the adverse counsel due to the
distance of his law office address and the lack of field staff of
undersigned counsel at this time.

Don Aba