Answer: Regional Trial Court
Answer: Regional Trial Court
Answer: Regional Trial Court
ABC BANK,
Plaintiff,
CIVIL CASE NO. 23457
-versus-
For: Collection of Sum of
Money
SPS. JOHN DOE and JANE DOE,
Defendants.
x------------------------------------------x
ANSWER
DEFENDANT SPS. JOHN DOE and JANE DOE, by counsel respectfully states:
Admissions/Denials
2. Paragraphs 10 and 11 of the complaint are denied insofar as the defendants has no
knowledge or information sufficient to form a belief as to the veracity of the
averments for the reasons stated in the Affirmative Defenses below.
Affirmative Defenses
3. Defendants reiterates, repleads and incorporates by reference all the foregoing insofar
as they are material and additionally submit that the complaint should be dismissed
on the grounds that:
3.2 Demand letter was not given to the defendants before filing the said
complaint.
3.3 The credit card was lost and the plaintiff was immediately notified about it
in person and defendants was required to furnish Affidavit of Loss. A
copy of of Affidavit of Loss is hereto attached as Annex “B”.
Counterclaim
4. Defendants reiterates, repleads and incorporates by reference all the foregoing insofar
as they are material and additionally submit that he is entitled to relief arising from
malicious and baseless suit, as follows:
By:
CARLO PABLO ALFONSO
IBP No. 12356874
PTR No. 98674, Makati City
MCLE Compliance No. 5647687
Roll No. 12345
ANNEX A
ANNEX B