Republic of the Philippines

REGIONAL TRIAL COURT OF NEGROS ORIENTAL

Region VII
BRANCH_____
Dumaguete City

ALBATROS LENDING CORPORATION

Plaintiff,

-versus- CIVIL CASE NO. M-2017-123

For: Sum of money and damages

MICHELLE GREEN
Defendant,

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ANSWER AND COUNTERCLAIM

DEFENDANTS, by counsel, before this Honorable Court, in answer to the

complaint most respectfully allege that-

1. ADMIT paragraphs 1 and 2 of the complaint.

2. ADMIT paragraphs 3 of the complaint with qualification that the interest
asked is against public policy.
3. Plaintiffs claim is not yet due and demandable.

COUNTERCLAIM

DEFENDANTS hereby incorporate by way of reference all the allegations of

the foregoing allegations in the Answer and Special/Affirmative Defenses and most
respectfully state furthermore that:
4. As a consequence of plaintiffs unreasonable conduct in filing this groundless
and unwanted suit, answering defendant Michelle Green was shocked and suffered
tremendous worries, sleepless nights, wounded feeling, anxiety, besmirched reputation
and similar injuries, plaintiff should be held liable to pay the sum of P500,000 as moral
damages.
 5. In order to serve as example to deter others from doing a similar act of the
public good, plaintiff must be held liable to pay the sum of P500,000 as exemplary
damages.
6. Defendants incurred litigation expenses in the sum of P10,000.

PRAYER

WHEREFORE, IN VIEW OF ALL THE FOREGOING, it is most respectfully

prayed of this Honorable Court that judgment be rendered in favor of defendants and
against plintiff:
1- DISMISSING the instant complaint.
2-ORDERNG defendant to pay the following sums:
2.1 - P500,000 - as moral damages;
2.2 - P500,000- as exemplary damages;
2.3 - P50,000 - as attorneys fees plus P2,000 appearance fee for every
court assignment;
2.4 - P10,000 - as initial litigation expenses.

Defendants further pray for such reliefs and remedies as are consistent with law,
justice and equity.

RESPECTFULLY SUBMITTED.
Dumaguete City, April 5, 2017.

ABC, CDE, DEG & ASSOCIATES LAW OFFICE

Counsel for the Defendant
2/F Portal West Silliman Avenue Dumaguete City

By:Jenifer V. Bendijo
Roll of Attorney No. 45969
PTR No. 123456; 01-02-01 / Dumaguete City
IBP Life Member Roll No. 445789/07-08-01 / Dumaguete City
MCLE Compliance No. III-897656 / 12-10-01