Republic of the Philippines

REGIONAL TRIAL COURT

6th Judicial Region
Branch 12
Makati City

Monkey D Luffy Plaintiff, CIVIL CASE No. 16-0956-2341

- versus – FOR: COLLECTION OF SUM OF

MONEY.

Trafalgar Law Defendant.

x- - - - - - - - - - - - - -- - - - x

ANSWER

Defendant, thru the undersigned counsel, most respectfully file their

ANSWER in response, to the complaint of the Plaintiff and avert that:

1. The defendant admits paragraph 1 and 2 of the complaint.

2. The defendant admits that he took a loan from Plaintiff but specially
deny paragraph 3 of the complaint. The true on the matter is, when
they signed the pro forma promissory note from the plaintiff there
was no detail with regards to the interest rates and other charges the
plaintiff is responsible for.
3. The defendant admits paragraph 4, 5, 6 of the complaint regarding
the owner of the motor vehicle, but deny about the paragraph about
the Deed of Assignment all terms and conditions were fully explain
properly.

4. The defendant especially deny paragraph 7 as defendant literally full

filled his obligation by paying full the loan agreement in May 2017 .
Photocopies of the Deposit/Loading slip are here to attach and mark
as Annex “A”.
 5. Defendant deny paragraph 8 as the defendant have no sufficient
knowledge about it.

Affirmative defense

1. Article 1231 of the Civil Code: Obligations are extinguished by

payment or performances
2. Article 1235. When the obligee accepts the performance, knowing its
incompleteness or irregularity, and without expressing any protest or
objection, the obligation is deemed fully complied with.

WHEREFORE, PREMICES CONSIDERED, defendant respectfully pray

that the instant complaint be immediately dismiss for lack of merit.

BARAG LAW OFFICE

Counsel for the Defendant
7-C Crispa Ave., San Lorenzo Village,
Pamplona III, 1712 Makati City
E-mail: barag.law@gmail.com

By:

Marlon Sy
Roll No. 52354
PTR No. 101229105-J/01-04-2016
IBP No. 1017535/01-04-2016
MCLE Compliance No. V-0023447
dated April 11, 2016

Copy furnished:

ATTY. Raposon
Counsel for the Plaintiff
XXXXX

BT
STF Law Firm, Suite 704, Hi-Residences Bldg.,
23th ST. Bonifacio High Taguig City

VERIFICATION
 I, Trafalgar Law, of legal age and Filipino, after having been duly
sworn to in accordance with law, depose and state THAT:

I am the defendants in the above entitled case; I have caused the

preparation of the foregoing document and I have read the same and the
contents of which are true and correct of my own knowledge and/or on the
basis of authentic documents.

AFFIANT SAYETH NAUGHT.

In witness whereof, I hereunto affix my signature this May 10, 2018.

TRAFALGAR LAW
DEFENDANT

REPUBLIC OF THE PHILIPPINES)

MAKATI).

SUBSCRIBED AND SWORN to before me this May 10, 2018;

defendant exhibiting to me his TIN I.D. No. 108-555-758-00.

WITNESS MY HAND AND SEAL this May 10, 2018.