REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Manila
Branch 1
MICHAEL BADIRRI,
Plaintiff,

NO. 12345

-versus-

CIVIL CASE

EDIL FRANCISCO,
Defendant.
x--------------------------------------------x
ANSWER

1.
2.

3.

4.

COMES NOW, the defendant, through the undersigned counsel

and unto this Honorable Court, most respectfully avers:
That he ADMITS the contents of paragraph 2 only insofar as his
personal circumstances are concerned;
That he ADMITS his obligation of paying the monthly
installments cited in paragraph 3 of the complaint, but DENY the rest
of the allegations therein as said defendants obligation to plaintiff is
not for the exercise of a right to repurchase but for the amortization of
a loan that he acquired from the plaintiff at an interest of 12% per
annum;
That defendant is without knowledge or information sufficient to
form a belief as to the veracity of the averments in paragraph 4 of the
complaint;
That defendant does not, at the moment, have all the records of
payments he made to plaintiff, so that he also does not have

information sufficient to form a belief as the truth of the allegations in

paragraph 5 of the complaint and, therefore, DENY them.
WHEREFORE, the defendant respectfully prays that the
complaint be dismissed with costs against the plaintiff.
Other relief and remedies as may be deemed just and
equitable under the premises are likewise prayed for.
City of Manila, September 27, 2012.
GACUTAN AND SALAZAR LAW OFFICE
Counsel for the Defendant
Suite 258 The Tower
Malate, Manila
By:
ARVIN GACUTAN
Roll No. 98765
IBP No, 12345/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila
Copy furnished:
ATTY. FRETTI LAUREL
Counsel for the Plaintiff
Unit 1234 Laurel Building
Sampaloc, Manila
EXPLANATION
Copy of the foregoing ANSWER was served to plaintiffs
counsel by registered mail due to time and distance constraints and
for lack of the undersigneds staff who can serve the same in person.

ARVIN GACUTAN