REPUBLIC OF THE PHILIPPINES

National Capital RegionCity of MANILA

MUNICIPAL TRIAL COURTBranch No. _____

MARIA S. DALUZPlaintiff

-------- versus--------- Civil Case No. _________For: Ejectment

Pedro P. PalmaDefendant

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

ANSWER

COMES NOW the defendant by the undersigned attorney and in answer to

plaintiff’s complaint, respectfully avers:

1. That he denies paragraphs 2 and 3 of the complaint; and, that he is without

knowledge to form a belief as to the truth of the averments made in them;

2. That he denies specifically each and every material allegation made in the

complaint and alleges that he has been the owner and occupant of the

disputed piece of property located at 1028 Ibarra St., Sampaloc, Manila; and

that, he has been given the right to own and occupy the aforementioned

property by its’ owner, Mario Juan since 1975;

3. And as an affirmative defense, the defendant alleges that he has received

only one (1) and not two (2) demand letters as stated in the paragraph 3 of

the plaintiff’s complaint, contrary to the allegation of the existence of a final

letter of demand;

4. As counterclaim, the defendant alleges against the plaintiff that the latter has

been harassing and causing undue emotional stress to him and his family by

pursuing this suit and thereby placing him and his family in constant fear of

losing their family home.

WHEREFORE, it is respectfully prayed that:

A. After due hearing, judgment be rendered in favor of the defendant for

ownership and occupancy of the above-mentioned premises;

B. That judgment be rendered in favor of the defendant with respect to

counterclaim; and,

C. For such other relief consistent with law and equity and for costs.

IN WITNESS WHEREOF, this 14th of July, 2011.

(Signed)

Atty. Alan D. Maligalig

Maligalig, Mabalisa, & Associates

810 Kadiwa St., Quiapo, Manila 1001