Republic of the Philippines MUNICIPAL TRIAL COURT Branch 1 San Juan RAPHAEL GARCIA, plaintiff, versus CLAUDIA JUNGOY,

accused, x----------------------------x ANSWER COMES NOW, the accused, through the undersigned counsel and unto this Honorable Court, most avers: 1. That accused ADMITS the allegations in paragraphs 1 and 2 of complaint; 2. That accused ADMITS the allegations in paragraph 3 of complaint, to the effect that he issued a BPI Check 21365, in the amount of One Hundred Eighty Thousand Pesos only (P180,000.00) for the payment of the loan accomodation. A true and faithful machine reproduction of said check is hereto attached as Annex 1; 3. That the said check is drawn in the accused's account at BPI with Account No. 00252200-28; 4. That accused ADMITS the allegations in paragraph 4 of complaint, to the effect that, on October 5, 2008, he issued the check to plaintiff at the time the latter sent a demand letter. Said demand letter is hereto attached as Annex 2; 5. That, on the same date, accused accompanied the plaintiff to encash the check and thereafter made an acknowledgment receipt as a proof of herein accused's payment. Said acknowledgment receipt is hereto attached as Annex 3; 6. That on November 28, 2008, a formal demand letter was received by the accused informing the latter of his debt to plaintiff; 7. That due to unfounded suit filed by the plaintiff, accused suffered sleepless nights, Criminil Case No. 12345 For: Violation of B.P. 22

serious anxiety in which case he should be awarded moral damages in the amount of P180,000.00; 8. That the accused secured the services of a counsel and paid the amount of Thirty Thousand Pesos (P30,000.00) as and by way of attorney's fees. WHEREFORE, the accused prays for judgment. 1. Dismissing the complaint with costs against the plaintiff; and 2. Moral damages of P180,000.00 and attorney's fees of P30,000.00. 3. Other relief and remedies as may be deemed just and equitable under the premises are likewise prayed for. Quezon City, Manila, December 12, 2008. ATTY. MO AKO Counsel for the Accused Suite 305 Puzon Bldg., E. Rodriguez Avenue, Q.C. IBP No. 1111111/2-5-05/Mla. PTR No. 22222222/9-21-05/Mla. Roll No. 333333

V E R I FI C A T I O N I, CLAUDIA JUNGOY, of legal age, Filipino citizen, single, and resident of #823 Domingo St., Sta. Ana Subd., Quezon City, after having been duly sworn to in accordance with law do hereby depose and say: 1. That I am the accused in the above-entitled case; 2. That I have caused the preparation of the foregoing Answer and have read the allegations contained therein; 3. The allegations in the said Answer are true and correct of my own knowledge and

authentic records. IN WITNESS WHEREOF, I have hereunto affixed my signature this 12th day of December 2008, in the City of Quezon. (Sgd.) Claudia Jungoy SUBSCRIBED AND SWORN to before me this 12th day of December 2008, in the City of Quezon, affiant exhibiting to me her PRC License I.D. No. 098766 issued at Quezon City on September 2, 2008. Doc. No. 3; Page No. 3; Book No. 3; Series of 2008. CC: ATTY. GILIAN SANTOS S. ASTONIDA Counsel for the Plaintiff Office of the City Prosector San Juan EXPLANATION OF SERVICE Copy of the Answer was served to the counsel for the plaintiff by registered mail due to time and distance constraints, and for lack of the undersigned's staff who can serve the same in person. JESSE JR. L. GALIAS