REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Manila
Branch 1

JASMINE,
Plaintiff,

-versus- CASE NO. 12345
FOR: TRESPASS

ABC CORPORATION,
Defendant.
x--------------------------------------------x
ANSWER


COMES NOW, the defendant, through the undersigned counsel and unto this Honorable
Court, most respectfully avers:

1. That defendant admits the averments in paragraphs 2,3 and 4 of the complaint;

2. That defendant does not, at the moment, have all the records of payments made by the
plaintiff; so that, they do not have sufficient information to form a belief as to the truth
of the allegations in paragraphs 6 and 7 of the complaint, therefore, deny them.

3. That defendant, without knowledge to form a belief as to the veracity of the averments in
paragraph 8 of the complaint;

4. That defendant denies, specifically each and every material allegations made in
paragraphs 9, 10 and 11 of the complaint; and alleges that, according to the contract to
sell, in the case where the plaintiff fails to pay within the agreed period stated therein, the
defendant may rescind the contract without need of any consent from the plaintiff.
Furthermore, the defendant does have a right to conduct inventory of items and
automatically repossesses or padlock the unit without judicial proceedings.


WHEREFORE, the defendant respectfully prays that the complaint be dismissed with costs
against the plaintiff.
0000000000 LAW OFFICE
Counsel for the Defendant
Suite 123 The Tower
Malate, Manila

By:
DEL DIMANAHAN
Roll No. 00000
IBP No, 0000/1-3-2012/Manila
PTR No. 00000/1-3-2012/Manila

Copy furnished:
ATTY. BLAH BLAH
Counsel for the Plaintiff
Unit 1234 Laurel Building
Sampaloc, Manila
EXPLANATION

Copy of the foregoing ANSWER was served to plaintiffs counsel by registered mail due
to time and distance constraints and for lack of the undersigneds staff who can serve the same in
person.

DEL DIMANAHAN