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Republic of the PhilippinesREGIONAL TRIAL COURT

BRANCH 19Justice Hall, Catarman, Northern Samar

JUAN DELA CRUZ,Plaintiff, Civil Case No. 3579

-versus For: Ownership andRecovery of Possession withDamages

PEDRO SANTOS ANDJOSE CRUZ,

Defendants.x------------------------------------------x

ANSWER

COMES NOW, defendant in the above-entitled case,through counsel, unto this Honorable Court, most respectfullystates:

1. Answering the allegations of Paragraph 1, DefendantPedro Santos admit each and every allegation contained in saidParagraph 1;

2. Answering the allegations of Paragraph 2 , DefendantPedro Santos allege that no information or belief sufficient to allow

to answer and so deny each and every allegation contained in saidParagraph 2;

3. Answering the allegations of Paragraph 3 , DefendantsPedro Santos allege that no information or belief sufficient to allow

to answer and so deny each and every allegation contained in said

Paragraph 3;

4. Answering the allegations in paragraph 4, Defendant PedroSantos specifically and categorically deny the allegation by plaintiffin Paragraph 4;

5. That the Katibayan ng Orihinal na Titulo submitted asannex A is a document issued by the Register of Deeds and form

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part of evidence of ownership of the stated property in the saidcertificate of title and the allegations in paragraph 5 whichDefendant Pedro Santos specifically deny has no basis since theplaintiff did not submit any documents of ownership in their name

suggesting true ownership of the parcel of land subject of this case;

6. Answering the allegations in Paragraph 6 Defendant denysuch allegations;

7. Answering the allegations in Paragraph 7, Defendantdeny such allegations;

8. Answering the allegations of Paragraph 8, DefendantPedro Santos allege that no information or belief sufficient to allowto answer and so deny each and every allegation contained in said

Paragraph 8;

AFFIRMATIVE DEFENSES

FIRST AFFIRMATIVE DEFENSE

The Complaint fails to state a cause of action against thisdefendant upon which relief may be granted, and therefore, it

should be dismissed.

SECOND AFFIRMATIVE DEFENSE

The claim is barred by applicable statutes of limitation

and should be dismissed.

THIRD AFFIRMATIVE DEFENSE

If Plaintiff suffered any damages, which is specifically

denied, said damages were proximately caused or contributed

to by acts or omissions of persons other than this Defendant,

for which this Defendant has no liability.

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WHEREFORE, Defendant prays that this Court dismiss theComplaint of the Plaintiff herein, with costs and disbursements toDefendant, together with such other relief the Court finds to be justand proper.

July 4, 2014

ATTY. HERARDO G HERMOSILLA

COUNSEL FOR DEFENDANTS

Roll No 56789IBP No 34567, PTR No 111213

MCLE Cert # IV-002-57 valid until 2015

VERIFICATION

I, Pedro Santos, am a defendant in the above-entitled action. Ihave read the foregoing and know the contents thereof. The same is

true of my own knowledge, except as to those matters which aretherein alleged on information and belief, and as to those matters, Ibelieve it to be true.

I declare under penalty of perjury that the foregoing is trueand correct and that this declaration was executed at Catarman,Northern Samar.

IN WITNESS WHEREOF, I have hereunto affixed mysignature this 4th day of July, 2014 in Catarman, Northern Samar

Philippines.

PEDRO SANTOSAffiant

CTR No. 1314156Issued at Catarman, Northern Samar

Issued on January 6, 2014

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SUBSCRIBED AND SWORN before me this 4th day of July2014, who exhibited to me his CTC No.1314156 issued on January

6, 2014 at Catarman, Northern Samar

Notary Public

ATTY. HERARDO G HERMOSILLA

Roll No 56789IBP No 34567, PTR No 111213

MCLE Cert # IV-002-57 valid until 2015My comm. Expires Dec. 31, 2014

Doc. No. .234...Page No. .25..;Book No. III..;Series of 2014_.