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F. Answer with Special and Affirmative Defenses and Counterclaim (Caption and Title) ANSWER COMES NOW, the defendant, through the undersigned counsel, in the above-entitled case and to this Honorable Court most respectfully alleges: 1. Defendant admits averment in paragraphs 1,2 and 3 of the complaint; 2. Defendant specifically denies the allegation in paragraph 4 of the complaint, the truth being that (fact being claimed by the defendant as the true state of facts or truth in the special and affirmative defenses herein set forth): 3. Defendant has no knowledge or information to form a belief as to the truth of the averment in paragraphs 5, 6, 7 and 8 of the complaint By way of special and affirmative defenses, the defendant avers: 1. The obligation has been paid 2. The cause of action has prescribed By way of counterclaim, defendant alleges: 1. That by virtue of this unwarranted and malicious act initiated by the plaintiff, the defendant was forced to engage the services of counsel in the sum of twenty-thousand pesos (P20,000). WHEREFORE, it is respectfully prayed that the complaint be dismissed and defendant be awarded the amount of __________ pesos (P _________). Other equitable reliefs are likewise prayed for. Place and date.
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Signature of Counsel
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