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    Answer To Complaint For Sum of Money

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    Lea Underscore
    The defendant Pedro Tan files an answer to a civil case filed against him by Juana Dela Cruz for collection of money. Tan admits some facts alleged in the complaint but denies owing any money. He claims the signature on the promissory note is forged. Tan also provides an alibi, attaching plane tickets showing he was on vacation in Manila on the date the complaint alleges he and the plaintiff met. Tan requests the court dismiss the complaint.

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    Answer To Complaint For Sum of Money

    Uploaded by

    Lea Underscore
    779 views4 pages
    The defendant Pedro Tan files an answer to a civil case filed against him by Juana Dela Cruz for collection of money. Tan admits some facts alleged in the complaint but denies owing any money. He claims the signature on the promissory note is forged. Tan also provides an alibi, attaching plane tickets showing he was on vacation in Manila on the date the complaint alleges he and the plaintiff met. Tan requests the court dismiss the complaint.

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    ANSWER TO COMPLAINT FOR SUM OF MONEY

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    The defendant Pedro Tan files an answer to a civil case filed against him by Juana Dela Cruz for collection of money. Tan admits some facts alleged in the complaint but denies owing any money. He claims the signature on the promissory note is forged. Tan also provides an alibi, attaching plane tickets showing he was on vacation in Manila on the date the complaint alleges he and the plaintiff met. Tan requests the court dismiss the complaint.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    779 views4 pages

    Answer To Complaint For Sum of Money

    Uploaded by

    Lea Underscore
    The defendant Pedro Tan files an answer to a civil case filed against him by Juana Dela Cruz for collection of money. Tan admits some facts alleged in the complaint but denies owing any money. He claims the signature on the promissory note is forged. Tan also provides an alibi, attaching plane tickets showing he was on vacation in Manila on the date the complaint alleges he and the plaintiff met. Tan requests the court dismiss the complaint.

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    © All Rights Reserved
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    Download as docx, pdf, or txt
    of 4

    REPUBLIC OF THE PHILIPPINES

    REGIONAL TRIAL COURT


    TENTH JUDICIAL REGION
    BRANCH 30,
    SURIGAO DEL NORTE

    JUANA DELA CRUZ,


    Plaintiff,
    Civil Case No. 123456
    - versus -
    FOR: Collection of Sum of Money
    PEDRO A. TAN,
    Defendant,
    x - - - - - - - - - - - - - - - - - - - -x

    ANSWER

    NOW COMES the defendant in the above entitled case, and to this
    Honorable Court most respectfully alleges:

    Defendant admits the averment in paragraph 1 and 2 of the complaint;

    1. Defendant specifically denies the allegation in paragraph 3 of the


    complaint insofar as it alleges that the defendant owes the plaintiff a
    sum of money and fails to pay the same, the truth being those alleged
    in the special and affirmative defenses part hereinbelow;

    1. Paragraphs 4 and 5 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;

    By way of special and affirmative defenses, defendant avers:

    1. The Plaintiff never gave the defendant the alleged amount of Four
    Hundred Thousand Pesos (₱400,000.00); that Defendant did not sign
    the alleged promissory note; and that Defendant’s signature is forged;

    2. On August 25, 2019, the Defendant and the Plaintiff did not see each
    other because the former was having a vacation in Manila as
    evidenced by the photocopy of the plain ticket, attached herein,
    marked as Annex “A”, and made an integral part hereto.

    Other equitable reliefs are likewise prayed for.

    Surigao City, Philippines, December 14, 2020

    1
    ATTY. LUCIO A. TAN
    Counsel for the Defendant
    TAN LAW OFFICE
    Rizal Street, Brgy Washinton, Surigao City
    Roll No. 654321
    PTR No 333333, May 25, 2019
    IBP No. 444444 Surigao City May 25, 2019
    MCLE Compliance No. 9876543

    VERIFICATION

    I, PEDRO A TAN, of legal age, Filipino, married, and a resident of


    #125 Lopez Jaena Street, Brgy. Washington, Surigao City, after being sworn
    in accordance with law, hereby depose and state that:

    a) I am the defendant in the above captioned case; I have caused


    the preparation of the foregoing answer;

    b) I have read the allegations contained therein; and

    c) I certify that they are all true and correct of my personal


    knowledge or based on authentic records.

    In witness whereof, I have hereunto set my hand this 14th day of


    December 2020 at Surigao City, Philippines.

    PEDRO A TAN
    Affiant
    PRC I.D. no. 123456

      

     SUBCRIBED AND SWORN TO before me this 14th day of


    December 2020 in Surigao City, Philippines, affiant exhibiting to me her
    PRC I.D. no. 123456 issued in Surigao City on June 30, 2013 and valid
    until June 30, 2020.

    ATTY. LUCIO A TAN


    Notary Republic for and in the city of
    Surigao
    2
    TAN LAW OFFICE
    Rizal Street, Brgy Washinton, Surigao City
    Roll No. 654321
    PTR No 333333, May 25, 2019
    IBP No. 444444 Surigao City May 25, 2019
    MCLE Compliance No. 9876543

    Copy furnished:

    ATTY. JEFFREY H. BORJA


    Counsel for Complainant
    #051 Narciso Street, Brgy. Taft, Surigao City
    Roll of Attorney No. 01234
    PTR No. 25643, Surigao City, January 10, 2019
    IBP No. 24358, Surigao City, January 4, 2019
    MCLE Compliance No. 012345

    3
    ANNEX A

    CEBU PACIFIC AIR

    BOARDING PASS No. 123456

    PASSENGER: PEDRO A. TAN


    FLIGHT No. PR 123 BXU-MNL
    DEPART: 08:00 08/24/2019
    ARRIVE: 09:45 08/24/2019

    CEBU PACIFIC AIR

    BOARDING PASS No. 654321

    PASSENGER: PEDRO A. TAN


    FLIGHT No. PR 123 MNL-BXU
    DEPART: 08:00 08/28/2019
    ARRIVE: 09:45 08/28/2019

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