REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

BRANCH 6
CITY OF TAGAYTAY
Mrs. Margarita Ynares, plaintiff
- Versus

Civil Case No.003

for: Unlawful Detainer

Virginia Wang, Defendant

Accompanied by her attorney-in-fact
Atty. Toby Emerson T. Pavon
x----------------------------------------------x
ANSWER
HERE, the plaintiff together with undersigned counsel brings to this
most honorable court, TO MOST RESPECTFULLY STATE THAT;
1. That she admits paragraph 1 as to the personal circumstances of both
parties.
2. That she admits paragraph 2 as to the ownership of the Plaintiff over
the property and paragraph 3 as to the existence of the said lease
agreement.
3. That she specifically denies paragraph 8 in that Defendant was made
to believe that Plaintiff would consider a renegotiation of the lease
agreement and that she would continue to lease the property in the
mean time.
4. That the Defendant denies paragraph 12 that any attempts were made
by Plaintiff to reoccupy the manor as both parties have already begun
re-negotiations of a new lease agreement for the property.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed to this
Honorable Court that the case be dismissed for lack of cause of action.
Such other reliefs and remedies under the premises are likewise
prayed for.
City of Tagaytay, Philippines, this April 1, 2015
Toby Emerson Pavon
Counsel for the Plaintiff
PTR No. 1654891:7-09-06:B.C.
IBP No. 549621:7-09-06:B.C.

Roll No. 6546216:7-30-99: Manila

1 Infinite Loop Drive, Paco Building
Paco, Manila
VERIFICATION AND CERTIFICATION
I, Ms. Virginia Wang, of legal age, single, a Filipino citizen
and a resident of Pasay, after being sworn according to law, hereby
depose and state that:
1. I am the Defendant in this proceeding.
2. I have read and understood the filed complaint and the allegations
therein.
Virginia Wang
Defendant
In witness thereof, I, Mr. Toby Emerson Pavon, counsel of the
plaintiff, have hereby set my hand this 1st day of April, 2015, at the City of
Tagaytay.
Toby Emerson Pavon
Counsel for the Defendant
PTR No. 1654891:7-09-06:B.C.
IBP No. 549621:7-09-06:B.C.
Roll No. 6546216:7-30-99: Manila
1 Infinite Loop Drive, Paco Building
Paco, Manila

Copy furnished to Atty. John Doe, counsel for Plaintiff.

Served personally to and received by Atty. John Doe.