Answer With Counterclaim - Complaint For Collection Of Sum Of Money 6n3o4d

[Court] [Region] [COURT] [City], [Branch No.] [NAME]__________, Plaintiff, Civil Case No. ___________ For: Collection of Sum of Money

- versus [NAME]__________, Defendant. x ----------------------------------- x ANSWER (With COUNTERCLAIM) DEFENDANT, by counsel, respectfully states that: issions/Denials

1. He its the contents of paragraph 1 only insofar as his personal circumstances but specifically denies the contents insofar as plaintiff’s personal circumstances for the reason stated in the Affirmative Defenses below. 2. He its the contents of paragraph 2 only where it states that a Contract of Lease was entered into but specifically denies that the Contract reflects the true intent of the parties as explained in the Affirmative Defenses below. 3. He its the contents of paragraph 3 only as to the fact that demand to vacate was made but specifically denies its contents as to the truth of the reasons for the letter for lack of knowledge sufficient to form a reasonable belief as to its truth or falseness. 4. He specifically denies the contents of paragraphs 4 to 6 for the reasons stated in the Affirmative Defenses below. Affirmative Defenses 5. Defendant reiterates, repleads and incorporates by reference all the foregoing insofar as they are material and additionally submit that the Complaint should be dismissed because: 5.1. [STATE DEFENSES] 5.2 [STATE DEFENSES] Counterclaim 6. Defendant 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 the filing of this malicious and baseless suit, as follows: 6.1. Moral Damages amounting to [AMOUNT IN PESOS IN BOTH LETTERS AND FIGURES] because [STATE REASONS FPR THE CLAIM] ____________________.

6.2. Attorney’s Fees amounting to [STATE AMOUNT IN PESOS IN BOTH LETTERS AND FIGURES] _________________ because he was compelled to secure services of counsel to vindicate his legal rights.

WHEREFORE, Defendant respectfully prays that judgment be rendered in his favor by 1. dismissing the Complaint, and 2. granting defendant’s counterclaim by awarding defendant a. [AMOUNT IN PESOS] ____________ as Moral Damages, and b. [AMOUNT IN PESOS] _____________________ as Attorney’s Fees. Other just and equitable reliefs are prayed for.

[CITY] ____________; [DATE] __________. [SIGNATURE] [NAME] _____________ Counsel for Plaintiff [ADDRESS] ______________________

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING I, [NAME] ___________, of legal age, do hereby state that: I am the defendant in the case filed by [PLAINTIFF’S NAME] _______________ for [TYPE OF CASE FILED] ____________; in response, I have caused the preparation of this Answer with Counterclaim; I have read its contents and affirm that they are true and correct to the best of my own personal knowledge; I specifically deny the genuineness and due execution as well as the binding effect of the actionable documents pleaded by plaintiiff; I hereby certify that there is no other case commenced or pending before any court involving the same parties and the same issue and that, should I learn of such a case, I shall notify the court within five (5) days from my notice. IN WITNESS WHEREOF, I have signed this instrument on [DATE] _________. [SIGNATURE] [NAME] ______________

SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day of [MONTH AND YEAR]_________________, affiant exhibiting before me his Government Issued ID no. _______________ issued on [DATE}__________________ at [PLACE OF ISSUANCE]_____________________. [SIGNATURE] [NAME]_______ Notary Public Until [DATE]__________________ PTR No. [NUMBER] ____________

Issued at [PLACE]______________ On [DATE] ___________________ Doc. No. Page No. Book No. Series of [YEAR] ___________. Copy furnished through personal service: [NAME OF COUNSEL] __________________ Counsel for the Plaintiff [FIRM NAME] _______________ [ADDRESS] ________________ [USE THE FOLLOWING IF SERVICE IS NOT MADE PERSONALLY] Copy furnished through ed mail: [NAME OF COUNSEL] __________________ Counsel for the Plaintiff [FIRM NAME] _______________ [ADDRESS] ________________ Registry Receipt No. ________ Post Office ________________ Date _____________________ EXPLANATION The foregoing [DESIGNATION OF PLEADING, MOTION, ETC] _______________and its attachment were served on [NAME OF COUNSEL] ________________ by ed mail instead of personal service as counsel for petitioner [STATE REASON] ___________________. [SIGNATURE] [NAME] _________________

Republic of the Philippines City of _______________

) ) s.s. AFFIDAVIT

I, [NAME] ____________ , a messenger of [NAME OF COUNSEL FOR DEFENDANT], with office address at [ADDRESS] __________________, after being duly sworn, deposes and states: That on [DATE] ______________________, I served a copy of the following pleadings/papers by ed mail in accordance with Section 10, Rule 13 of the Rules of Court: Nature of Pleading/Paper [STATE PLEADING/PAPER SENT] ________________________ in Case No. [CASE NUMBER] _________________ entitled [TITLE OF CASE] ____________________ by depositing a copy in the post office in a sealed envelope,

plainly addressed to [NAME OF PARTY/ATTORNEY] _______________ at _______________ with postage fully paid, as evidenced by Registry Receipt No. _____________________ attached and with instructions to the post master to return the mail to sender after ten (10) days if undelivered. TO THE TRUTH OF THE FOREGOING, I have signed this Affidavit on [DATE] ________________, in the City of [CITY] _____________, Philippines. [SIGNATURE] [NAME] __________ Affiant SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day of [MONTH AND YEAR]_________________, affiant exhibiting before me his Government Issued ID no. _______________ issued on [DATE}__________________ at [PLACE OF ISSUANCE]_____________________. [SIGNATURE] [NAME]_______ Notary Public Until [DATE]__________________ PTR No. [NUMBER] ____________ Issued at [PLACE]______________ On [DATE] ___________________ Doc. No. Page No. Book No. Series of [YEAR] ___________.