REPUBLIC OF THE PHILIPPINES

FIFTH JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITY
Legazpi City
NGATASYA GUTTIEREZ,
Plaintiff,
-versus- CIVIL CASE NO. _________
For : Unlawful Detainer
JEANE NAPULIS,
Defendant.
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ANSWER
COMES NOW, the defendant, through the undersigned counsel and unto
this Honorable Court, most respectfully avers:
1. That she ADMITS the contents of paragraph 1 only insofar as her
personal circumstances are concerned; but she denies that she is singly residing
in the said apartment as she lives with her 11-year-old son.
2. That she ADMITS the contents of paragraph 2 except that she is
occupying Unit 1 of the said studio-type apartment;
3. That she ADMITS her obligation of paying the monthly installments cited
in paragraph 3 of the complaint;
4. That she DENIES the allegation that the continuous refusal of payment of
the agreed rental was without justification.
That the Php. 28,000.00 payment agreed upon in the Barangay
Conciliation was already paid through and by deducting the expenses incurred
for the repair of damages caused by the typhoon Jeje last May 25, 2013 as
shown in the Appendix __; the expenses for the repair amounted to _____ as
shown by the receipts. (Appendices __, ___, __).
5. That she ADMITS the contents of paragraph 5;
6. That she ADMITS the contents of paragraph 6 only insofar as to the
submission of the matter before the barangay justice system, but DENIES the
allegation of failure to make good of her promise to pay as stipulated in the
kasunduan since both parties made a new agreement as to the method of the
payment of the said obligation stipulated in the kasunduan.
The defendant, here, EXPLAINS the circumstances of the new method of
payment as agreed by both parties:
Defendant gave a written notice on May 26, 2013, about the damages incurred
caused by the typhoon Jeje. Plaintiff in her reply letter dated May 27, 2013 said
Puonan nyo na patrabahuan yan, kung guranu man ang magastos nyo ibawas
na sana duman sa pinagkasunduan ta sa barangay ta wara kami matataong
kwarta ngunyan ta kaipuhan mi man ipaayos digdi samo. (Appendix __)
7. That she ADMITS the contents of paragraph 7 only insofar as to the letter
of demand dated August 1, 2013 but DENIES the receipt of the second demand
letter on July 15, 2013, which was actually on July 17, 2013.
That on July 15, 2013, plaintiff went to the unit occupied by the defendant,
supposedly to serve the second demand letter, however only the son was at
home. Plaintiff harassed the child causing the defendant to report the incident to
the nearby police station as evidenced in Appendix __;
8. That she ADMITS the contents of paragraph 8 only insofar as to the series
of letters of demand which were repeated by oral demands but DENIES as to
refusal to pay the agreed amount.

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.
Legazpi City, September 11, 2013.