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Republic of the Philippines MUNICIPALT TRIAL COURT DARAGA, ALBAY CONCHITA SANTOS, Plaintiff, Civil Case No.

__12345___ - versus FOR: Ejectment EDWIN REYES, Defendant, x-----------------x

ANSWER
COMES NOW the defendant by the undersigned attorney and in answer to plaintiffs complaint respectfully avers: 1. That he admits paragraph 2 of the complaint in so far as his personal circumstances; 2. That he admits the contents of paragraph 3, 4, and 5 where it states a Contract of Lease of a residential house was entered into; 3. That he denies the averments made in paragraph 6 about the failure to pay monthly rentals for five months for the reason stated in the affirmative defenses below; 4. That he admits the contents of paragraph 7 as to the stipulation of the contract; 5. That he admits that he received a demand letter but denies the contents thereof as explained in the affirmative defense below; AFFIRMATIVE DEFENSES 6. Defendant reiterates and alleges in so far as they are materially submit that the Complaint be dismisses because: 6.1 The defendant did not fail to pay monthly rentals starting March 29, 2012 to present or for five months since payment was made on March 29, 2012 as shown in the receipt attached in Annex 1; 6.2 The demand letter (Annex B) dated July 25, 2012 stated that defendant failed to pay 5 months rentals when in fact as of that date it is only almost four months.

PRAYER WHEREFORE, Defendant respectfully prays that judgment be rendered in his favor by dismissing the complaint. Other just and equitable reliefs are prayed for. Legazpi City, 3rd day August, 2012.

VILLARUEL-REYES LAW OFFICE Counsel for the Defendant Door No. 2, CJ-A Bldg., Old Albay, Legazpi City By: JOSH A. LOPEZ Roll No. 58923 IBP O.R. No. 22897 Legazpi Chapter PTR No. 7734951 E

ANNEX 1

RECEIPT
___________________

No. Date: __________________

Received from ____________________________________________ the sum of ____________________________________ (P_________) as payment for ____________________________________________ ___________________

may entry tlga po dapat iyan. Mejo waley su answer ko dgd. Haha. Pede iyan na may counterclaim pa. check mo nlng su legal forms.

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