Republic of the Philippines

Municipal Trial Court

City of Malolos

Madelene M. Mirasol,
Plaintiff
-versus-

Civil Case No. 00082

Mardie Angelo F. Briones,

Defendant
x-----------------------------x

ANSWER

DEFENDANT, thru the undersigned counsel unto this honorable court, most
respectfully states that:
Admissions/Denials
1. The defendant admits the contents of paragraph 1 only insofar as his
personal circumstances but specifically denies the contents insofar as
plaintiffs personal circumstances for the reason stated in the affirmative
Defenses below;
2. The defendant admits the contents of paragraph 2 only where it states that
he borrowed money from the plaintiff but specifically denies the other
allegations as explained in the Affirmative Defenses below;
3. The defendant specifically denies the contents of paragraphs 4, 5 and 6
for the reasons stated in the Affirmative Defenses below;
Affirmative Defenses

4. Defendant reiterates, repleads and incorporates by reference all the

foregoing insofar as they are material and additionally submit that the
complaint should be dismissed because:
4.1. The complaint fails to state a cause of action as the total amount
borrowed was already paid by the defendant. A copy of the receipt
that is signed by the defendant is herein attached as ANNEX A.
Counterclaim
5. Defendant reiterates, repleads and incorporates by reference all the
foregoing insofar as they are material and additionally submit that he is
entitled to relief arising from the filing of this malicious and baseless suit,
as follows:
5.1. Moral damages amounting to Sixty Thousand Pesos (P60,000.00)
because his name and reputation were besmirched by this
malicious and baseless suit;
5.2. Attorneys fees amounting to Fifty Thousand Pesos (P50,000.00)
because he was compelled to secure services of counsel to
vindicate his legal rights.

WHEREFORE, Defendant respectfully prays that judgment be rendered in his

favor by dismissing the complaint and granting defendants counterclaim.
Other just and equitable reliefs are prayed for.
City of Malolos; 28 July 2015

ATTY.
Roni C. Marquez
Counsel of the Defendant
City of Malolos, Bulacan
Copy furnished
ATTY. Christian D.J. Salvo
Counsel of the Plaintiff

City of Malolos, Bulacan

VERIFICATION
I, MARDIE F. BRIONES, of legal age, do hereby state that: I am the
defendant in this case filed by Ms. Madelene M. Mirasol for collection of money;
in response, I have caused the preparation of this Answer with Counterclaim; I
have read its contents and affirm that they are true and correct to the best of my
own personal knowledge.

In witness WHEREOF, I have signed this instrument on 28 July 2015.

MARDIE ANGELO FERDIE BRIONES

SUBSCRIBED AND SWORN to before me this 28th day of July 2015 at City of
Malolos, Bulacan.

FERNANDO OPEDA
Notary Public
PTR No. 012345