Republic of the Philippines

Regional Trial Court

Surigao City, Branch 29

DIANNE FAITH M. UY
Plaintiff,
-versus-

Civil Case No. _______

For: Sum of Money

PAOLA C. REGALADO,
Defendant.
x----------------------------------------------/
ANSWER
(With Affirmative Defenses)
Defendant, by counsel, respectfully avers that:
ADMISSION/DENIAL
1. Paragraphs 1 and 2 of the Complaint are admitted insofar as they
relate to the personal circumstances of the parties;
2. Paragraphs 3 and 4 are admitted insofar as it state that the defendant
incurred indebtedness of five hundred thousand (Php 500,000.00) and
executed promissory note in favor of the plaintiff;
3. Paragraphs 5 is specifically denied the truth being that the allegation
is maliciously false and that the defendant had already paid to the
plaintiffs agent JOLLY CUBILLAN the following amounts: Php
250,000.00
on November 1, 2013 and Php 250,000.00 on May1,
2014 (photocopies
of payment receipts are hereto attached as
annex A-1 and A-2);
4. Paragraph 6 is neither confirmed nor denied, not being statements of
ultimate facts, but the reliefs demanded by the plaintiff.
AFFIRMATIVE DEFENSES
5. That the pleading asserting the claim states no cause of action;

6. That the claim or demand set forth in the plaintiffs complaint has
been paid;
-BY WAY OFCOUNTER CLAIM
7. As a proximate cause in filing this baseless suit, defendant engaged
the services of the undersigned Law Office in the contractual sum of
Ten Thousand pesos (P10,000.00), which amount should be assessed
against
plaintiff, exclusive of appearance fee of counsel pegged at
P1,000.00 per hearing;
8. In order to serve as a lesson and a forewarning against plaintiff who
have the temerity to institute baseless suits, rather indiscriminately, the
award of exemplary damages in the amount of Twenty Thousand pesos
(P20,000.00) for defendant is warranted
PRAYER
WHEREFORE, PREMISES CONSIDERED, it is respectfully
prayed of this Honorable Court that, after due notice and hearing, the
instant case be DENIED, for having been anchored on distorted facts,
and for utter lack of merit.
Defendant prays for such other reliefs deemed just and equitable
under the circumstances.
MOST RESPECTFULLY SUBMITTED.
Surigao City, Philippines, 6 December 2014.

RALNA DYAN T. FLORANO

Roll No. 82489

Counsel for the Plaintiff

PTR No. 2408989, 1-07-13, Surigao City
IBP Lifetime No. 092417
MCLE Compliance No. III-0002453
FLORANO LAW OFFICE
1703 M. Ortiz St., Brgy. Washington, Surigao City

VERIFICATION
I, PAOLA C. REGALADO, Filipino, of legal age, single and a
resident of Navarro St., Brgy. Taft, Surigao City after having been
sworn to in accordance with law, depose and say THAT:
1. I am the defendant in the above-captioned case, I caused the
preparation of the foregoing Answer and have read and understood
the contents of the same; and that
2. All the allegations therein are true and correct to the best of my
personal knowledge and based on authentic documents.
WITNESS my hand this 6th day of December 2014 in Surigao City,
Philippines.
PAOLA C. REGALADA
Affiant
SUBSCRIBED AND SWORN TO BEFORE ME, this ______ day of
December 2014 in Surigao City, Philippines, after affiant exhibited to me
his Voters Identification Card No. 1234567, bearing his picture and
signature, serving as competent evidence of his identity.

Annex A-1
PAYMENT RECEIPT
November 1, 2013
Received from PAOLA C. REGALADO the amount of Two Hundred
Fifty Thousand Pesos (Php 250,000.00) representing the advance payment
of her Five Hundred Thousand Pesos debt.
Received by:

JOLLY D. CUBILLAN
As agent of Dianne Faith M. Uy

Annex A-2

PAYMENT RECEIPT
May 1, 2014
Received from PAOLA C. REGALADO the amount of Two Hundred
Fifty Thousand Pesos (Php 250,000.00) representing the payment for the
remaining balance from her Five Hundred Thousand Pesos debt.
Received by:

JOLLY D. CUBILLAN
For Dianne Faith M. Uy