Republic of the Philippines

METROPOLITAN TRIAL COURT

National Capital Judicial Region
Branch 41, Quezon City

CLEVELAND INDUSTRIES, Civil Case No. M-QZN-18-

INC., 08499-CV
Plaintiff,
For: Sum of Money with
-versus- Damages

TESSIE O. TAN LIM, doing

business under the name
and style “WILSIE
ENTERPRISES”,
Defendant.
x--------------------------------x

ANSWER

DEFENDANT TESSIE O. TAN LIM, unto this Honorable Court

most respectfully states that:

1. Paragraphs one (1), two (2), three (3), four (4), five (5), and six
(6) of the Complaint are admitted;

2. Paragraphs eight (8) and nine (9) of the Complaint are denied
for lack of knowledge or information sufficient to form a belief as to
the veracity or falsity thereof, the allegations therein being matters
known only to and are within the control only of the plaintiff;

3. Paragraph seven (7) of the Complaint is partially denied insofar

as it alleges that the defendant refuses to pay her outstanding
obligation to plaintiff up to the present;

SPECIAL AND AFFIRMATIVE DEFENSE

1. Since the year 2015, the Defendant’s business, Wilsie

Enterprises, has suffered a financial setback incurring several bad
debts and closure of customer’s accounts amounting to almost Two
Million Pesos, and has not yet recovered from such financial crisis
since then;

2. On March and April 2018, Mr. William O. Tan Lim, General

Manager of Wilsie Enterprises, repeatedly communicated via phone
the defendant’s financial predicament to Mr. Alvin Sy, the General
Manager of Cleveland Industries, Inc., and begged for their kindness
and indulgence to extend to Defendant another extension of time to
settle their unpaid obligations thru installment payment each month
on a mutual agreeable amount;

3. However, despite the Defendant’s request, the petitioner did

not heed into any compromise.

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is respectfully

prayed to this Honorable Court that petitioner’s complaint be denied
for lack of merit; and that the Court will order the parties to come up
with a mutual agreement as to the payment of terms on defendant’s
unsettled obligations.

Other reliefs just and equitable under the premises are likewise
prayed for.

Caloocan City, September 12, 2018.

By:

TESSIE O. TAN LIM

Defendant
 VERIFICATION and CERTIFICATION OF NON-FORUM
SHOPPING

I, TESSIE O. TAN LIM, of legal age, Filipino, married, and a

resident of 152 N. Carpio St., 6th Avenue, Caloocan City, after having
been duly sworn to in accordance with law, hereby depose and state
that:

1. I am the defendant in the above-stated case;

2. I have caused the preparation and filing of the foregoing

Answer and have read the allegations therein, and that they are true
and correct of my personal knowledge and belief and based on
authentic documents;

3. I have not commenced any other action or proceeding

involving the same issues before the Supreme Court, Court of
Appeals or any other tribunal or agency and, to the best of my
knowledge, there is no such action or proceeding pending before any
tribunal;

4. If I should learn that a similar action or proceeding has

been filed or is pending before the Supreme Court, Court of Appeals
or any other tribunal or agency, I undertake to report that fact within
five (5) days therefrom to this Honorable Court

IN WITNESS WHEREOF, I have hereunto set my hand this

________________________, 2018 in ___________________________.

TESSIE O. TAN LIM

Affiant

SUBSCRIBED AND SWORN to before me this

__________________________ in ________________________________,
affiant exhibiting to me her _________________________________ with
ID No. ____________________________________________ issued on
_________________________________________________ as competent
proof of her identity.

Notary Public
Doc. No.: __________
Page No.: __________
Book No.: __________
Series of 2018