Republic of the Philippines

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Branch 5,Manila

DSG
Plaintiff,

-versus- Civil Case No.19-12345-CC

For: Unlawful Detainer and
Damages
REM,
Defendant.
x- - - - - - - - - - - - - - -- - -x

REPLY

Plaintiff, through counsel and unto this Honorable

Court, most respectfully manifest that on 12 November
2019, she received a copy of the ANSWER (with
COUNTERCLAIM) of Defendant in the above-entitled case
and, by way of a REPLY to new matters allege therein,
state that:

1. Paragraphs 7, 8, 9,10 and 11 are specifically

denied, the truth being is that alleged in the
complaint wherein Plaintiff is the absolute owner
and title holder of the subject property and is not
co-owned with the Defendant;

2. Paragraphs 12, 13, 14, and 15 are specifically

denied for lack of sufficient information or
knowledge as to the truth or falsity thereof;

3. Paragraph 11 and 18 are denied as Plaintiff has no

knowledge of the building a house on the subject
property nor the approval of said construction;

4. Paragraph 7 is specifically denied as the real

property tax presented by Defendant is only a mere
evidence of payment of tax on property. As
 reiterated, Plaintiff is the absolute owner and title
holder of the subject property.

5. Paragraph 22 is denied for the Complaint filed with

is based in valid ground, and the imputation of
malice and bad faith, as well as the claim for
damages and attorney’s fees is baseless and lacks
sufficient information or knowledge as to the truth
and falsity thereof;

6. Plaintiff reiterates that this is a case of unlawful

detainer and the issue is possession and not
ownership of the subject property which may be
threshed out in a different proceeding so as not to
unduly delay the reliefs Plaintiff is entitled thereto
by the malicious ploy of Defendant to delay
disposition of the ejectment proceeding by raising
the issue of co-ownership.

WHEREFORE, premises considered, it is most

respectfully prayed of this Honorable Court that the
counterclaim of the Defendant be dismissed and the case
be now set for preliminary conference to a date
convenient to the calendar of the Honorable Court.

Other just and equitablereliefs are likewise prayed for.

Sampaloc, Manila 13 November 2019.

CANANUA MANGALUS AND ASSOCIATES

Counsel for Plaintiff
Lifetime IBP No. 0123456
PTR No. 01234 J/01-01-19/MM
Roll No. 01234/July 5, 2006
MCLE No. V-01234
102 Manila Hyatt Regency Ermita Manila
Tel No. (02)80123456; (02)80123457
Mobile No. 09123456789
Email: associates@cmassociates.com.ph
Copy furnished:

GMAD LAW OFFICE

Suite 258 The Tower
Malate, 1004 Manila
Email add.: gmadlaw@gmail.com
Tel No.: (02) 521-7767

ATTY. GEE A. PASTOR

ATTY. MELANIE R. BARRIOS
ATTY. ANGELI AMOR R. NAME
ATTY. DEXTER DEL ROSARIO
Counsels for Defendant
 VERIFICATION/ CERTIFICATION

I, DSG, after having been duly sworn to in

accordance with law do hereby depose and say:

1. That I am the plaintiff in the above-

entitled case;
2. That I have caused the preparation of the
foregoing complaint and I have read the same
and the contents hereof are true and correct
of my own knowledge or based on authentic
records;
3. That 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 an d, to the
best of my knowledge, no such other action or
claim is pending therein ;and
4. That if I should thereafter learn that a
similar action or proceeding has been filed or
is pending in the Supreme Court, the Court
of Appeals or any other tribunal or agency, I
hereby undertake to report such fact to the
Honorable Court within five (5) days
therefrom.

IN WITNESS WHEREOF, I have hereunto affixed my

signature this 14th of November, 2019.

DSG
Affiant

SUBSCRIBED AND SWORN to before me this 13th of

November 2019, in the City of Manila, affiant exhibiting
to me her PRC license No. 0123456 issued by the
 Professional Regulations Commission on 25th of July,
2018 at the City of Manila.

SUBSCRIBED AND SWORN to before me this

13th November 2019 in the City of Manila, affiant
exhibiting to me his Lifetime IBP ID No.0123456.

HERBERT ODSINADA
Notary Public (Office Address)
Under Appointment No.NN-18-005 158 A.H. Lacson St.,
Until December 31,2019 Sampaloc, Manila
PTR No. 11810535L/02-15-17/MM Tel. No.851-1879
LIFETIME IBPNO.02520 Cel No. (0917)422-5897
Roll No. 51600/April 15, 2008 E-mail:
odsinadahb@gmail.com