REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
City of Makati
Branch 143

MS. CYNTHIA A. RAMO,

Plaintiff,
CIVIL CASE NO._________
For: Support with prayer for Support
-versus- Pendente Lite

MR. KARL KENNY RAMO

Defendant.

X____________________________x

ANSWER

COMES NOW, the defendant, through counsel and to this Honorable

Court, respectfully avers:

1. That defendant admits to the allegations made by the plaintiff on

paragraphs 1 and 2 with regard to the personal circumstances of the
plaintiff and defendant;

2. That defendant admits to the statement made by the plaintiff on

paragraph 3;

3. The defendant admits to the statement made by the plaintiff made on

paragraph 4;

4. That defendant specifically denies the allegation made by the plaintiff

on paragraph 5, the truth being that defendant is willing to give
support to the children but cannot do so because of financial
constraints. The defendant also denies the allegation of abandonment,
when in fact, it was plaintiff who left without any pretenses;

5. That defendant specifically denies the allegation made by the plaintiff

on paragraph 6, the truth being that plaintiff is able to work but
refuses to work for reasons unbeknownst to the defendant. The
defendant also denies the allegation that he is lucratively employed, as

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 the matter of fact, defendant is experiencing financial constraints due
to unemployment;

6. That defendant specifically denies the computation made by the

plaintiff on paragraph 7, in truth, the amount should be lowered,
considering the modest life ensured by a lower amount and the
financial constraints the defendant is currently experiencing;

7. The defendant admits the allegation made by the plaintiff on

paragraph 8;

8. The defendant specifically denies the allegation made by the plaintiff

on paragraph 9, the truth of the matter is that the parents of the
plaintiff are well-off and had sufficient funds to support children;

9. The defendant denies any knowledge as regards the allegation

mentioned in paragraph 10, as defendant has no contact with the
plaintiff after their separation on starting on the year 2000.

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that, after hearing, judgment be rendered:

a) Dismissing the Complaint;

b) Ordering the plaintiff to pay the herein defendant the following sums:

1. The sum of P10,000 as and by way of attorney’s fees, and P2,000 as

appearance fee for every hearing of the case;

2. Costs of suit.

Defendant prays for such other reliefs as may be just and/or equitable in the
premises.

Makati City, Philippines, November 5, 2019.

ATTY. MARY GOLD BROCALES

Counsel for Defense
IBP Lifetime No. 123456/ 1/18/15
PTR NO. 1902345/1-14-19/Mla.
Roll No. 789012
MCLE Exemption No. V 0007819/8-15-19

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 VERIFICATION

REPUBLIC OF THE PHILIPPINES)

City of Makati )

I, Karl Kenny Ramo, of legal age, Filipino, after being sworn in

accordance with law, hereby depose and say:

1. That I am the defendant in the above-entitled case;

2. That I have caused the preparation of the foregoing Answer;
3. That I have read and understood the allegations therein, and
they are true and correct according to my knowledge and belief and
authentic records.

IN WITNESS WHEREOF, I have hereunto set my hands this 05th of

November, 2019, at Makati City, Philippines.

Karl Kenny Ramo

AFFIANT

SUBSCRIBED AND SWORN to before me, this 05th day of November,

2019, at Makati City, Philippines, affiant exhibited his Driver’s License No.
02-1234556 issued at LTO Quezon City, on November 7, 2018.

KARLA TERCERO
Notary Public
Until December 31, 2020
Per Notarial Commission No. M-111 Makati City
IBP No. 914129; January 3, 2013; Makati Chapter
PTR No. 4224356; January 3, 2019 Makati City
Roll No. 48348

Doc. No.___________
Page No.__________
Book No.__________
Series No._________

Copy Furnished:
ATTY. IVAN SALANGUIT
Suite 123, Rufino Bldg,
Makati City, Metro Manila