LegForms - 071718

DIAZ, Francis C.
July 17, 2018

2017400143 Legal Forms
Answer with Specific Denial
REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT
LEGASPI CITY, ALBAY
POTTER, Harry CIVIL Case No: 1016

Plaintiff, For: Unlawful Detainer
-versus-
GRANGER, Hermione
Defendant,
x------------------------------------------x
ANSWER
(In Re: Complaint, Received on June, 2018)
NOW COMES the defendant in the above entitled case, and to this
Honorable Court most respectfully alleges:
1. Defendant admits the averment in paragraph 1, 2, and 3

of the complaint;
2. Defendant specifically denies the allegation in paragraph

5 of the complaint, the truth being that defendant has
been performing his obligation from February 1, 2015 up
to February 1, 2016.
3. Defendant has no knowledge or information to form a

belief as to the truth of the averment in paragraphs 5 of
the complaint;
THAT Defendant specifically denies under oath the genuiness and due
execution of the Contract of Lease, a copy of which is attached to
DIAZ, Francis C. July 17, 2018
Plaintiff’s complaint as “Annex A”, the truth being that his signature
thereon is forged and that he did not in fact sign the said instrument
WHEREFORE, it is respectfully prayed that the complaint be

dismissed.
Other equitable reliefs are likewise prayed for.
Legaspi City, July 17, 2018.
Atty. Francis C. Diaz

Counsel for the Defendant
#0143 Burgundy Tower,
Ayala Ave., Makati City
VERIFICATION and CERTIFICATION AGAINST FORUM SHOPPING
I, Hermione GRANGER, of legal age, single, Filipino, and with postal

address c/o Barangay Mainit, Legaspi City, under oath, depose:
1. I am the defendant in the foregoing case; that I caused the

preparation of the foregoing Answer;
2. I have read its contents; and
3. The same are true and correct of my own direct, personal

knowledge.
Further, pursuant to Rule 7 of the 1997 Rules of Civil Procedure and

existing Supreme Court circulars, I hereby certify that I have not
heretofore commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency; that to the best of my knowledge, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency; and that if I should hereafter learn that
other similar or related actions or proceedings has been filed or is

pending before the Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this court.
Legaspi City, July 2018.
Hermione Granger
Defendant
SSS ID No: 109424
SUBSCRIBED and sworn to before me in Legaspi City on July 17,

2018, the defendant showing his SSS Member ID Card as stated
above as competent proof of his identity.
Atty. Ronald Weasley

Notary Public
Doc. No.: 08
Page No.: 08
Book No.: 08
Series of 2018
Answer with Cross Claim

LEGASPI CITY, ALBAY

-versus-
GRANGER, Hermione
Defendant,
x------------------------------------------x
ANSWER

of the complaint;


the complaint;
By way of counterclaim, defendant alleges:

1. That by virtue of this unwarranted and malicious act

initiated by the plaintiff, defendant was forced to engage
counsel in the sum of P10,000.00.
WHEREFORE, it is respectfully prayed that the complaint be dismissed

and defendant be awarded the amount of P5,000.00.




knowledge.

Hermione Granger
Defendant
SSS ID No: 109424


Notary Public
Doc. No.: 08
Page No.: 08
Book No.: 08
Series of 2018
Answer with Affirmative and Negative Denial

LEGASPI CITY, ALBAY

-versus-
GRANGER, Hermione
Defendant,
x------------------------------------------x
ANSWER

of the complaint;


the complaint;
By way of affirmative and negative defenses, defendant avers:

1. That the obligation has been paid;
2. That the defendant had lease said house and lot from
plaintiff and paid said monthly obligation;
3. That there is no cause of action against the defendant.
WHEREFORE, it is respectfully prayed that the complaint be

dismissed.




knowledge.


Hermione Granger
Defendant
SSS ID No: 109424


Notary Public
Doc. No.: 08
Page No.: 08
Book No.: 08
Series of 2018
Petition for Injunction with Affidavit of Injunction

SUPREME COURT
MANILA, NCR
POTTER, Harry G.R. No: 101678

Petitioner,
-versus-
GRANGER, Hermione
Respondent,
x------------------------------------------x
PETITION
NOW COMES the Petitioner, BY THEMSELVES, in the above-entitled

case, unto the Honorable Supreme Court, most respectfully avers
THAT:
1. Petitioner is of legal age, Filipino citizen, single, and a

resident of Hogwarts st., Alabang, Muntinlupa City. And that
Respondent is also of legal age, Filipino citizen, single, a
resident of Muggle st., Alabang, Muntinlupa City.
2. On 20 March 2015, petitioner received a copy of a Notice

to Vacate issued by the Office of the Clerk of Court and Ex-
Officio Sheriff of Muntinlupa City based on the Writ of
Execution dated 27 January 2012 issued by the Hon. Albus
Dumbledore, Housing and Land Use Arbiter of the HLURB
Expanded National Capital Region Office. Said notice is
giving herein petitioner ten (10) days to voluntarily vacate
and peacefully turn-over/surrender possession of our
respective occupied premises embraced and described in

TCT NO. PT 121274 to respondent.
3. This petition is an offshoot of a complaint filed by the

Respondent on 24 January 2007 seeking judicial
confirmation of herein petitioner from membership to
respondent association and from enjoyment of the
premises they are now occupying by means of eviction.
4. Petitioners, being not fully lettered with the intricacies and

technicalities of the law, gave so much trust and confidence
to their former counsel. The case treaded various courses
without petitioners knowing the possible outcomes but
resulted into gaining unfavorable judgment.
5. Petitioners can no longer afford to engage the services of a

counsel and they submitted for consideration of the Most
Honorable Court that they are litigating the instant case by
themselves. Again, herein petitioner most respectfully
submit to the Most Honorable Court to consider that the
absence of a counsel on record should not affect their
assertion of enforcing they legal rights
6. There is no appeal or any plain and speedy remedy in the

ordinary course of law that could resolve this very important
matter. Except, to beseech the Most Honorable Court to
use its expansive powers to review cases and
controversies, including the duty to settle actual
controversies involving rights which are legally demandable
and enforceable, and to determine whether or not there has
been a grave abuse of discretion amounting to lack or in
excess of jurisdiction on the part of any branch or
instrumentality of the government.
7. The instant petition involves petitioners who questioned the

manner respondents ignored requirements laid down by
law and established jurisprudence, which would result in
the unfair administration of justice, satisfied the existence

of justiciable controversy.
8. The heart-breaking result of the present controversy

emanated from the gross negligence of the petitioners’
counsel applying the doctrine “negligence of the counsel is
negligence of the client.” However, herein petitioners
believe that their present plight is an exception to the
doctrine. The Most Honorable Court, in the long line of
cases decided admitted exceptions to the general rule
when: (1) the client is deprived of due process, (2) the
application of the general rule will result in outright
deprivation of client’s liberty or property, and (3) where the
interest of justice so requires, and accord relief to client
who suffered by reason of lawyers gross negligence.
WHEREFORE, premises considered, Petitioner most respectfully

prays of the Most Honorable Court the following
1. That this Petition be given due course;
2. That a Preliminary Mandatory Injunction and/or Temporary

Restraining Order be issued pending resolution of the
instant petition;
3. That after notice and hearing, a final order be issued:

SETTING ASIDE AND OVERRULING HLURB ENCRFO 21
January 2010 Decision and to forestall 27 January 2012
Writ of Execution.
Other reliefs and remedies, which are just and equitable, are likewise
prayed for.
Muntinlupa City; 26 March 2015
Harry Potter
Petitioner
VERIFICATION and DECLARATION OF NON- FORUM SHOPPING
I, Harry Potter, Filipino and of legal age, and presently residing in

Hogwarts st., Alabang, Muntinlupa City, after having been duly sworn
on oath, hereby deposes and states THAT:
1. I am the Petitioner in the above-entitled petition;
2. I caused the preparation and filing of the above Petition for

for the Issuance of Preliminary Mandatory Injunction and all
the allegations thereon were read by us and we found them
to be true and correct of my personal knowledge and based
on authentic records;
3. Further, pursuant to Rule 7 of the 1997 Rules of Civil

Procedure and existing Supreme Court circulars, I hereby
certify that I have not heretofore commenced any other
action or proceeding involving the same issues in the
Supreme Court, the Court of Appeals, or any other tribunal
or agency; that to the best of my knowledge, no such action
or proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency; and that if I should
hereafter learn that other similar or related actions or
proceedings has been filed or is pending before the
Supreme Court, the Court of Appeals, or any other tribunal
or agency, I undertake to report that fact within five (5) days
Muntinlupa City, July 2015.
Harry Potter
Petitioner
SSS ID No: 109424
AFFIDAVIT OF INJUNCTION
Harry Potter, of legal age and resident of the City of Muntinlupa,

Philippines, after having been duly sworn in accordance with law,
hereby deposes and says:
That he is the Petitioner in the above entitled case and is entitled to the
relief demanded in the complaint in whole or in part and such other
relief consists in restraining the commission or continuance of the acts
complained of either for a limited period or perpetually;
That the commission or continuance of the acts complained of during

the litigation will work injury to herein plaintiff and that the defendant is
doing, threatens, or is about to do, or is procuring or suffering to be
done the acts tending to render the judgment ineffectual;
And that he is willing and ready to file a bond in the amount which may
be fixed by the Court to the effect that he, the plaintiff, will pay
the defendant all the damages which the latter may sustain by reason
of the injunction if the court should finally decide that the plaintiff was
not entitled thereto.
Harry Potter
Affiant
SUBSCRIBED and sworn to before me in Muntinlupa City on July 17,


Notary Public
Doc. No.: 08
Page No.: 08
Book No.: 08
Series of 2018
Petition of Habeas Corpus

REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
CITY OF MANILA
GRANGER, Hermione S.P. No: 101678

Petitioner,
-versus-
POTTER, Harry
Respondent,
x------------------------------------------x
PETITION
NOW COMES the Petitioner, BY THEMSELVES, in the above-entitled

case, unto this Court, most respectfully avers THAT:
1. Petitioner is the mother of the minors Albus and Severus

Potter, who were born out of the valid marriage between
petitioner and respondent.
2. The marriage failed and petitioner has been living

separately from respondent since 2004. Sometime in
February 2016, respondent, unknown to petitioner,
abducted the minor children and has kept them
incommunicado and out petitioners reach.
3. Being below seven (7) years of age, custody of the minors

is naturally presumed to belong to petitioner, as their
mother.

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DIAZ, Francis C.

July 17, 2018

Answer with Specific Denial

REPUBLIC OF THE PHILIPPINES

POTTER, Harry CIVIL Case No: 1016

1. Defendant admits the averment in paragraph 1, 2, and 3

2. Defendant specifically denies the allegation in paragraph

3. Defendant has no knowledge or information to form a

WHEREFORE, it is respectfully prayed that the complaint be

Other equitable reliefs are likewise prayed for.

Legaspi City, July 17, 2018.

Atty. Francis C. Diaz

VERIFICATION and CERTIFICATION AGAINST FORUM SHOPPING

I, Hermione GRANGER, of legal age, single, Filipino, and with postal

1. I am the defendant in the foregoing case; that I caused the

2. I have read its contents; and

3. The same are true and correct of my own direct, personal

Further, pursuant to Rule 7 of the 1997 Rules of Civil Procedure and

other similar or related actions or proceedings has been filed or is

Legaspi City, July 2018.

SUBSCRIBED and sworn to before me in Legaspi City on July 17,

Atty. Ronald Weasley

Answer with Cross Claim

REPUBLIC OF THE PHILIPPINES

POTTER, Harry CIVIL Case No: 1016

1. Defendant admits the averment in paragraph 1, 2, and 3

2. Defendant specifically denies the allegation in paragraph

3. Defendant has no knowledge or information to form a

By way of counterclaim, defendant alleges:

1. That by virtue of this unwarranted and malicious act

WHEREFORE, it is respectfully prayed that the complaint be dismissed

Other equitable reliefs are likewise prayed for.

Legaspi City, July 17, 2018.

Atty. Francis C. Diaz

VERIFICATION and CERTIFICATION AGAINST FORUM SHOPPING

I, Hermione GRANGER, of legal age, single, Filipino, and with postal

1. I am the defendant in the foregoing case; that I caused the

2. I have read its contents; and

3. The same are true and correct of my own direct, personal

Further, pursuant to Rule 7 of the 1997 Rules of Civil Procedure and

Legaspi City, July 2018.

SUBSCRIBED and sworn to before me in Legaspi City on July 17,

Atty. Ronald Weasley

Answer with Affirmative and Negative Denial

REPUBLIC OF THE PHILIPPINES

POTTER, Harry CIVIL Case No: 1016

1. Defendant admits the averment in paragraph 1, 2, and 3

2. Defendant specifically denies the allegation in paragraph

3. Defendant has no knowledge or information to form a

By way of affirmative and negative defenses, defendant avers:

1. That the obligation has been paid;

3. That there is no cause of action against the defendant.

WHEREFORE, it is respectfully prayed that the complaint be

Other equitable reliefs are likewise prayed for.

Legaspi City, July 17, 2018.

Atty. Francis C. Diaz

VERIFICATION and CERTIFICATION AGAINST FORUM SHOPPING

I, Hermione GRANGER, of legal age, single, Filipino, and with postal

1. I am the defendant in the foregoing case; that I caused the

2. I have read its contents; and

3. The same are true and correct of my own direct, personal

Further, pursuant to Rule 7 of the 1997 Rules of Civil Procedure and

heretofore commenced any other action or proceeding involving the

Legaspi City, July 2018.