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REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES


City of Cebu
Branch 01

PEDRO SANTOS,
Plaintiff , Civil Case No. 1
-Versus- For:
INJUNCTION
BRUNO RAMOS
Defendant.
x----------------------------x

ANSWER WITH COUNTERCLAIM

Defendant, through the undersigned counsel, most respectfully files

his Answer in response to the Complaint of the Plaintiff and interposes as

well his counterclaim against the latter, to wit:

ADMISSIONS AND DENIALS

1. That paragraphs 2,3, 4,5,6,7 and 8 are admitted;


2. That paragraphs 9 and 10 are admitted only insofar as his personal

circumstances are concerned;


3. That the allegation in paragraph 11 is denied as the same is an

erroneous conclusion made by Plaintiffs;


4. That paragraph 12 and the rest of the allegations are denied for lack

information or knowledge sufficient to form a reasonable belief

thereof;

SPECIAL DEFENSES

5. That the Complaint filed by Plaintiff is nothing but a malicious

lawsuit calculated to harass the Defendant, not to mention it does

not state a cause of action and is a clear resort to forum-shopping,

thereby rendering it dismissible outright;


6. That by filing this legal action, it is crystal clear Plaintiff have only

resorted to the contemptuous act of forum-shopping;

BY WAY OF COUNTERCLAIM

7. Due to the malicious filing of this instant suit, Defendant have hired

the services of the undersigned counsel for an agreed amount of

Forty Thousand Pesos (Php 40,000.00) and have suffered anxiety,

mental anguish, sleepless nights and besmirched reputation which

when quantified in monetary terms is in the amount of One Hundred

Thousand Pesos (Php 100,000.00).

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PRAYER

WHEREFORE, in view of the foregoing, Defendant most respectfully

pray for the dismissal of the Complaint and the award of counterclaim to

him. Other reliefs are likewise prayed for.

EXPLANATION

Copy of the foregoing ANSWER was served to plaintiffs counsel by

registered mail as personal service is impracticable as the said Counsels

address in not specified.

City of Cebu, February 12, 2017.

CDE LAW OFFICE


Counsel for the Defendant
2/F Aznar Bldg. Urgello St.,
Cebu City, Philippines

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ATTY. DARYL TEJANO
PTR No. 111111 / 02-20-2017 / Cebu City
IBP LRN No. 111-11 / 12-31-2017 / Cebu City
Roll of Attorney No. 11111
MCLE Exemption no. III-11111

ATTY. JOSHUA
MANINANTAN
PTR No. 222222 / 02-22-2017 / Cebu City
IBP LRN No. 222-22 / 12-21-2017 / Cebu City
Roll of Attorney No. 22222
MCLE Exemption no. III-22222

Copy furnished:

ATTY. RODEL V. REYES


Counsel for the Plaintiff
Unit 108, Ben Tower I
Cebu City, Philippines

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