Answer To Complaint
Answer To Complaint
Answer To Complaint
ANSWER
1. Paragraphs one (1) and two (2) of the Complaint are admitted;
2. Paragraphs three (3) and four (4) of the Complaint are denied
for lack of knowledge or information sufficient to form a belief as to
the veracity or falsity thereof, the allegations therein being matters
known only to and are within the control only of the plaintiff;
1. On May 25, 2015, the Defendant and the Plaintiff did not see
each other because the former was having a vacation in Baguio
City as evidenced by the photocopy of entry/exit of vehicles
monitoring sheet, attached herein, marked as Annex A, and made
an integral part hereto. Such monitoring sheet is issued by the
Gate Security Department of the Subdivision where the Defendant
resides.
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Complaint
3. On November 5 and November 6, 2015, the Defendant and
the Plaintiff did not see each other because the former visited her
late grandmother in San Pedro, Laguna as evidenced by the
photocopy of entry/exit of vehicles monitoring sheet, attached
herein, marked as Annex B, and made an integral part hereto.
Such monitoring sheet is issued by the Gate Security Department
of the Subdivision where the Defendant resides.
COMPULSARY COUNTERCLAIM
PRAYER
By:
TRIVEN P. CASTILLO
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Complaint
Roll of Attorney No. 45969
PTR No. 123456; 01-02-01 / Lipa City
IBP Life Member Roll No. 445789/07-08-01 / Lipa City
MCLE Compliance No. III-897656 / 12-10-
TRIVEN P. CASTILLO
Notary Public
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Complaint
Valid Until December 31, 2015
Roll of Attorney No. 45969
PTR No. 123456; 01-02-01 / Lipa City
IBP Life Member Roll No. 445789/07-08-01 / Lipa City
MCLE Compliance No. III-897656 / 12-10-01
Doc. No.: 49
Page No.: 8
Book No.: II
Series of 2015
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Complaint