REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH 74 TAGUIG

JUAN DELA CRUZ,

Plaintiff.
CIVIL CASE NO. 12345
-versus- For: Unlawful Detainer
PEDRO RAMOS,
Defendant
X - - - - - - - - - - - - - - - - - - - - - - -X

ANSWER
(In Re: Summons, Received on __ March 2019)

The DEFENDANT Pedro Ramos, by counsel, respectfully states:

I. ANSWER

1. Paragraphs 1 to 4 of the Complaint are admitted.

2. Paragraphs 5 to 8 of the Complaint are denied due to lack of merit.

It has been duly proven (?) that the defendant as lessor, on several
occasions have validly offered a tender of payment but was likewise
unduly denied on all occasions by the Plaintiff-Lessee with no
proper reason whatsoever.

3. Paragraph 9 of the Complaint is admitted.

4. Paragraph 10 should likewise be not given any merit. In the present

case, it has been proven that the Defendant offered a valid tender of
payment and it was in fact the Plaintiff who continued to stubbornly
refuse in bad faith to accept such valid tender of payment.

II. SPECIAL AND AFFIRMATIVE DEFENSES

 5. That the obligation to pay the rent was validly fulfilled when there
was a valid tender of payment

6. That the Plaintiff refused without just cause

7. That the only remedy left for the Defendant was to consign in court

III. COMPULSORY COUNTERCLAIM

8. By reason of the abuse of right committed by the plaintiff and by

reason of such unjust refusal to accept a valid tender of payment (?)
the defendant was constrained to hire the services of a lawyer to
defend his rights and interests for a professional fee of P15,000 plus
P2,000 per court appearance;

9. Similarly, the plaintiff’s unfounded suit has caused the defendant

mental anguish and suffering and public humiliation and
embarrassment, for which the defendant claims moral damages of
P80,000.00. (there might be a limit on the numbers of these things
but d ko pa na reresearch)

IV. PRAYER

WHEREFORE, premises considered, it is respectfully prayed that

the parties be given ample time to reach an amicable settlement before the
City Mediation Center, and that in case of a failure thereof, and after trial,
the complaint be dismissed for lack of merit and the defendant’s compulsory
counterclaim be granted, i.e.. attorney’s fees of P15,000 plus moral damages
of P80,000.00, plus costs of suit.

The defendant respectfully prays for such and other reliefs as may
be deemed just and equitable in the premises.

Nacita, Maducdoc, Yap and Associates (N.M.Y.)

Law and Accounting Offices
Counsel for the Defendant
9th Avenue Bonifacio Triangle, 40th Street Taguig, Metro Manila
Tel. No. (02) 123 – 1234/0905-295-9016
Email: nmy.law@gmail.com
ATTY. JONATHAN RAYMOND GERARD YAP
Counsel for the Defendant
Roll of Attorneys No. 123469
PTR No. 1234567, 01-01-2025, Makati City
IBP No. 123456, 01-01-2025, Manila City
MCLE Compliance No. VI - 1234567
 VERIFICATION
AND
ANTI-FORUM SHOPPING CERTIFICATION

I, Jonathan Raymond Gerard G. Yap of legal age, married, Filipino,

and with postal address Block 10 Lot 16, Barangay. Cholpu G.M.A Cavite,
Under oath, depose:
I am the defendant in the foregoing case; that I caused the
preparation of the foregoing Answer; that I have read and understand its
contents; and that the same are true and correct of my own personal
knowledge and/or based on authentic records.
That I have not 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.

IN WITNESS WHERFOR, I have hereunto set my hand this 16th day of

March, 2019.

PEDRO RAMOS
Affiant

SUBSCRIBED AND SWORD to before me this 19th day of March, 2019

NOTARY PUBLIC