REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

Tarlac City
Branch __

ROBERTO SENTRY R. REYNALDO

Plaintiff,

Case No.
- versus -

FIREFOX IGNIGHTE, INC.,

CHRISTOPHER RONN G. PAGCO,
MA. SHIELA G. REYES,
ANIWAY BARCELONA, and
RENATO SILVESTRE
Defendants.
x-----------------------------------------------x

ANSWER

COMES NOW, defendants in the above-captioned case, through the

undersigned counsel and unto this Honorable Court, most respectfully avers:

1. That Defendants are the incumbent members of the Board of

Trustees of Firefox Ignighte Inc., a non-stock corporation organized
under the laws of the Republic of the Philippines with its principal
office at 2/F Tarlac State University School of Law, Tarlac City;

2. That Defendants DENIES that the plaintiff is a member of the

corporation duly appointed and made a corporate officer by the
Board of Trustees as General Counsel on January 28, 2019 during
the conduct of its 2nd board meeting;

3. That the board resolution was approved for the hiring of the Plaintiff
as General Counsel of the Corporation and not as a corporate
officer by the Board of Trustees;

4. That the corporate officers enumerated in Article III of the by-laws

of the Corporation are the exclusive officers of the Corporation and
the rest be considered only as employee or subordinate officials1;

1
MATLING INDUSTRIAL AND COMMERCIAL CORPORATION, RICHARD K. SPENCER, CATHERINE SPENCER, AND ALEX
MANCILLA, Petitioners, vs.RICARDO R. COROS, Respondent G.R. No. 157802, October 13, 2010
 5. That Defendant Barcelona DENIES the fact stated by the Plaintiff
under paragraph 4 and 5 of the complaint;

6. That Defendant Barcelona as one of the trustees of the Corporation

have a right to ask questions about the subject matter of every board
meetings and she have no intent to criticized the Plaintiff;

7. That Defendants notify the Plaintiff through its HR Officer to submit

a written explanation within (5) days from receipt why he should not
be terminated;

8. That despite such notification, the Plaintiff did not comply with the
period given to submit his written explanation wherein he violated
Article VI of the by-laws of the Corporation that “A member who
disobey and does not comply with the by-laws, rules and regulations
that may be promulgated by the association from time to time” will
cause his/her removal;

9. That Plaintiff in acting manner incompatible with the noble

objectives and policies of the Corporation shall be removed as
stated in Article VI of the by-laws of the Corporation “Removal shall
take place upon order of the Board of Trustees for any cause
deemed by it to be detrimental to the corporation or any of its
purpose”;

10. That Defendants DENIES that they acted in bad faith in the
removal of Plaintiff and shall be held liable since their act in
removing the Plaintiff is in accordance by the Corporation’s by-Laws
and the Revised Corporation Code;

WHEREFORE, the defendants respectfully pray that the complaint be

dismissed with costs against the Plaintiff.

Other relief and remedies as may be deemed just and equitable under
the premises are likewise prayed for.

City of Tarlac, May 05, 2019.

[sgd.]
ATTY. JEAH N. MELOCOTONES
Counsel for the Defendant
Roll of Attorneys No. 95362
IBP No. 683725/ 02-02-20/Tarlac City
PTR No. 8425`5/07-08-20/Tarlac City
MCLE Compliance No. V-0011472
Copy furnished:
MATTHEW MURDOCK MERCADO
Counsel for the Plaintiff
Unit 1010 Rosal Building
Tarlac City, Tarlac

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, ATTY. JEAH N. MELOCOTONES, of legal age, after having been

duly sworn in accordance with law, hereby depose and state that:

1. I am the duly authorized representative of the Defendant;

2. I have caused the preparation and filing of the foregoing Answer;
3. I have read the contents of the foregoing Answer;
4. I understood the contents of the foregoing Answer and attest to the
truthfulness and veracity of the contents thereof

IN WITNESS WHEREOF, I have hereunto set my hands this 02 day of

May 2019 at Tarlac City, Tarlac.

ATTY. JEAH N. MELOCOTONES

SUBSCRIBED AND SWORN TO before me, the Affiant exhibiting her

government issued Passport ID with serial no. 527354 as competent
evidence of her identity.

JENNIFER WALTERS-SANTOS
Notary Public
Roll No. 52094
Commission No. N-03
Valid Until: 31 December 2020
Brgy. Ligtasan, Tarlac City

Doc. No. ___;

Page No. ___;
Book No. ___;
Series of 2019.