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JAYPEE S. AMOR,
Respondent.
x------------x
REPLY
(to Answer dated August 15, 2014)
COMES NOW PLAINTIFF NOVIE E. DUNLAO, through
the undersigned counsel, unto this Honorable Court, most
respectfully manifests and avers:
1. Last August 15, 2014, the Plaintiff through counsel
received a copy of the Answer with Special and Affirmative
Defenses of the Defendant JAYPEE S. AMOR dated August
15, 2014;
2. The Defendants Answer to the Verified Complaint
contained the following denials:
a. That his place of residence has now changed
from Villa San Agustin, Brgy Estefania, Bacolod City to
#1376 Lucarno Street, Helvetia Heights Subdivision,
Bacolod City;
b. Specific denial of paragraphs 3, 4, 5, 6, 7, 10,
11, 12, 13, 15 and 16 of the Verified Petition for
allegedly containing inaccurate statements of facts;
c. Specific denial of paragraph 8 for being
allegedly bereft of factual and legal basis except for the
birth of their child HAILEY ANDREA DUNALO AMOR on
October 4, 2012;
agency yet for the month of June and July 2014 the
Petitioner never received any amount from the
Respondents mother nor was she ever contacted
nor visited by the same within the said months;
h. Contrary to his word, under paragraph 25, the
Respondent failed to provide for the support which their
child needed for her day to day expenses;
i.
It was only on August 2014, as alleged in
paragraph 26, that an amount of Five Thousand Pesos
(Php 5,000.00) was given to the Petitioner, through the
Petitioners counsel, for the support of their child. It is
very unfortunate that it had to take the Petitioner a
case formally filed in court for the Respondent to send
the basic support his very own child, whom he begot
with the Petitioner, needed;
j. Lastly, under paragraph 27, the Respondent
argues that the Hon. Court should give scant
consideration for the amount of indebtedness the
Petitioner seeks to recover as she incurred the same
due to the necessary expenses she had to shell out and
borrow from other individuals, specifically her sister, for
the needs of their child. However, it is clearly stated
under Articles 206 and 207 of the Family Code to wit:
Article 206. When without the
knowledge of the person obliged to give
support, it is given by a stranger, the
latter shall have a right to claim the
same from the former, unless it appears
that he gave it without any intention of being
reimbursed.
Article 207. When the person obliged
to support another unjustly refuses or fails to
give support when urgently needed by the
latter, any third person may furnish
support to the needy individual with a
right of reimbursement from the person
obliged to give support. This Article shall
apply particularly when the father or mother
of a child under the age of majority unjustly
LYNDON P. CAA
Counsel for the Plaintiff
Roll of Attorneys No. 36621
MCLE COMP. IV-0001227, 02-09-11
IBP OR No. 929280; 01-02-14
PTR No. 5441341; 01-02-14
nd
2 Gate Annex, Acacia Cor-Birch Roads
Villa Angela Subd., Brgy. Villamonte Bacolod City 6100
Tel./ Fax No. (034) 432-0516/ 7087872
COPY FURNISHED:
ATTY. AUDREY VIOLET A. LACSON
Unit 4 & 5 St., Francis Center
Singcang Araneta Streets, Bacolod City
RR No. ___________
August ___, 2014
EXPLANATION
Copy of the foregoing Reply was furnished to the other
parties by way of registered mail only and not by personal
service, by reason of lack of personnel to effect personal
form of service.
LYNDON P. CAA
Reply to Answer Dunlao/alluser/ilang