REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

City of Cebu
Branch 01

PEDRO SANTOS,
Plaintif , Civil Case No.
98765
-versus- For: INJUNCTION
BRUNO RAMOS
Defendant.
x----------------------------x

ANSWER WITH COUNTERCLAIM

Defendant, through the undersigned counsel, most respectfully file his

Answer in response to the Complaint of the Plaintif and interpose as well his
counterclaim against the latter, to wit:

ADMISSIONS AND DENIALS.

1. That paragraphs 2,3, 4,5,6,7 and 8 are admitted;

2. That paragraphs 9 and 10 are admitted only insofar as his personal
circumstances are concerned;
3. That the allegation in paragraph 11 is denied as the same is an erroneous
conclusion made by Plaintifs;
4. That paragraph 12 and the rest of the allegations are denied for lack
information or knowledge sufficient to form a reasonable belief thereof;

Special Defense

5. That the Complaint filed by Plaintif is nothing but a malicious lawsuit

calculated to harass the Defendant, not to mention it does not state a cause
of action and is a clear resort to forum-shopping, thereby rendering it
dismissible outright;
6. That by filing this legal action, it is crystal clear Plaintif have only resorted to
the contemptuous act of forum-shopping;

By Way of Counterclaim

7. Due to the malicious filing of this instant suit, Defendant have hired the
services of the undersigned counsel for an agreed amount of Forty Thousand
Pesos (Php 40,000.00) and have sufered anxiety, mental anguish, sleepless
nights and besmirched reputation which when quantified in monetary terms
is in the amount of One Hundred Thousand Pesos (Php 100,000.00).
 PRAYER

WHEREFORE, in view of the foregoing, Defendant most respectfully pray for

the dismissal of the Complaint and the award of counterclaim to him. Other reliefs
are likewise prayed for.

City of Cebu, February 12, 2017.

ATTY. DARYL TEJANO

Notary Public for Cebu City
Notarial Commission No. 123-45
expiring on
December 31, 2017; Roll of Attorney
No. 54321
PTR No. 678876; 02-20-2017, Cebu
City
Lifetime IBP No. 5678, 2/F Aznar
Bldg.
Urgello St., Cebu City, Philippines

EXPLANATION

Copy of the foregoing ANSWER was served to plaintifs counsel by registered

mail as personal service is impracticable as the said Counsels address in not
specified.

Copy furnished:

ATTY. RODEL V. REYES

Counsel for the Plaintif
Cebu City, Philippines