REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Manila
Branch 1

XIAN LAO,
Plaintiff,
CIVIL CASE No. 12345
-
versus- For: Collection of Sum
of Money with Damages

MATEO GO and
JOLO TREVOR
Defendants.

x--------------------------------------------x

ANSWER WITH CROSS-CLAIM

COMES NOW, the defendant, through the undersigned counsel and

unto this Honorable Court, most respectfully avers:

1. That he ADMITS paragraph 2 of the complaint;

2. That he DENIES paragraph 3 of the complaint, the truth being that it was the
defendant JOLO TREVOR who applied for and exclusively benefited from
the loan with the plaintiff, answering defendant acting as mere co-signer in
the promissory note to accommodate defendant TREVOR and to guarantee
the loan;

3. That he lacks knowledge or information sufficient to form a belief as to the

truth of the allegations contained in paragraphs 3, 4, and 5 of the complaint
and therefore, specifically DENIES the same;

SPECIAL/AFFIRMATIVE DEFENSES

4. That without the knowledge and consent of answering defendant, the principal
condition of the loan was changed and the term of payment thereof was
unreasonably extended by the plaintiff, to the prejudice of answering
defendant;

5. That there was undue delay on the part of the plaintiff in enforcing the
payment of the obligation, and the loan could have been paid immediately at
maturity had there been prompt and timely notification to answering
defendant of the non-payment of the loan by defendant TREVOR;
 CROSS-CLAIM AGAINST HIS CO-DEFENDANT

6. That defendant TREVOR should reimburse answering defendant on any and

whatever amount the latter may be held answerable or which he may be
ordered or suffered to pay under and by virtue of the present action in favor
of the plaintiff, answering defendant not having benefited whatsoever from
the loan which defendant TREVOR obtained from the plaintiff;
7.
8. That defendant TREVOR should pay plaintiff directly and fully on the
amounts claimed by the latter in its complain he having benefited directly and
exclusively from the transaction alleged in the complaint;

WHEREFORE, premises considered, answering defendant respectfully

prays to the Honorable Court to render judgment as follows:
1. By dismissing the complaint against answering defendant;
2. By ordering defendant TREVOR to pay directly and fully to the plaintiff the
amounts claimed by the latter in the complaint;
3. By ordering defendant TREVOR to pay answering defendant for any and
whatever amounts the latter may be held liable to or be ordered or suffered to
pay plaintiff under and by virtue of the plaintiff’s claim in the present action.
Answering defendant prays such other relief and remedies as may be
deemed just and equitable under the premises.

City of Manila, October 1, 2012.

MORALES AND ASSOCIATES LAW OFFICE

Counsel for the Defendant Mateo Go
Suite 109 Morales Tower
Paco, Manila

By:

ZEUS MORALES
Roll No. 12345
IBP No. 23456/1-18-2012
PTR. No. 34567/1-18-2012
 VERIFICATION / CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines )

City of Manila ) S.S.

I, MATEO GO, of legal age, Filipino citizen, single and resident of 234
San Bartolome St., Manila, after having duly sworn to in accordance with law,
do hereby depose and say that:

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

2. That I have caused the preparation of the foregoing ANSWER and have read
the allegations contained therein;

3. The allegations in said answer are true and correct of my own knowledge and
based on authentic records;

4. I hereby certify that I have not commenced any other action or proceeding
involving the same issues in any court, tribunal or quasi-judicial agency and,
to the best of my knowledge, no such other action or claim is pending therein;

5. If I should thereafter learn that a similar action or proceeding has been filed
or is pending, I hereby undertake to report that fact within five (5) days
therefrom to the court or agency where the original pleading and sworn
certification contemplated herein have been filed;

6. I executed this verification/certification to attest to the truth of the foregoing

facts and to comply with the provisions of Adm. Circular No. 04-94 of the
Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

1st day of October 2012, in the City of Manila.

MATEO GO

SUBSCRIBED AND SWORN TO before me this 1st day of October

2012, in the City of Manila, affiant exhibiting to me his SSS ID No. 123456
issued on January 5, 2012.

Doc. No. _______

Page No. _______
Book No. _______
Series of 2012.
Copy furnished:

ATTY. JADE GAYONDATO

Counsel for the Plaintiff
Unit 876 Gayondato Bldg.
Pandacan, Manila

JOLO TREVOR
Defendant
123 Singalong St.
Manila

EXPLANATION

Copy of the ANSWER was served by registered mail due to time and
distance constraints and for luck of the undersigned’s staff who can serve the
same in person.

ZEUS MORALES