The allegations in paragraph 6 in that, Defendants have made an admission of the adverse possession by the Plaintiffs of lots 5350-N and 5350-K which possession ripened into ownership by way of acquisitive prescription thereby making their total land area 10, 578 square meters are denied the truth being that stated in the affirmative and special defenses; 11. Said decision in the aforesaid eviction suit has reached the Supreme Court where the Plaintiffs either by themselves or through the corporate entity they represent, The Pearl of Boracay Landholdings Inc. intervened. both surnamed SANSON Plaintiff, -versus- CIVIL CASE No. ANSWER. TRUE OR FALSE. 12368 -versusPEDRO SANTOS Defendant, x-----x ANSWER WITH SPECIAL AND AFFIRMATIVE DEFENSES AND COUNTERCLAIM NOW COMES the defendant in the above entitled case, and to this Honorable Court most respectfully alleges: 1. 3212580 / 01-06-2010 / Quezon City, IBP LRN 02224 / 1-16-2001 / Caloocan City. The first two (2) lots (5350-B and 5350-F) are not being contested by any of the parties here, whether concerning their title or whoever is entitled to possession thereof. B. Sample answer: “I know that a call center is where people ask for support when they’re facing some issues and problems with a product or service. The allegations in paragraph 6b are denied the truth being that stated in the affirmative and special defenses hereunder; 12. Filipino, and with postal address c/o xxx, Barangay xxx, xxx Village, xxx, xxx 2 Answers. Philippines is an archipelago of 7,107 islands. The only strategical advantage comes when the plaintiff desires the defendant to file a verified answer. Iloilo City for Kalibo, November 25, 2004.”. The allegations in par. The poor on trial in the Philippine justice system. the distance of his law office address and the lack of field staff of Copy of this pleading was sent to the opposing counsel through registered mail as personal service is impracticable. Roxas City for Kalibo, Aklan, Philippines. Wall street journal, can answer philippines needs offenders: why … Why most Filipinos lack discipline in their own country. List of Pleadings Which Must Be Verified (Update #1) « Law Innovations (Philippines) – ndeed, the verification requirement has been the cause for minor paranoia among lawyers in the Philippines, and the prudential rule has emerged that whenever in doubt, verify. While the instant complaint is one titled for quieting of title or for removal of cloud of title, their parents and Plaintiffs themselves or through the corporate entity they represent, The Pearl of Boracay Landholdings, Inc. have been unceasingly resorting to all sorts of  legal actions just so Defendants become unsuccessful in their bid to regain possession of lots nos. Content. If the allegations of the complaint are sufficient... A proceeding is adversarial where the party seekin... Was the service of summons jurisdictional? 5350-N and 5350-K in a manner that was in the concept of owner, openly, adversely and continuously are concerned, since Defendants are without any knowledge or information sufficient to form a reasonable belief thereof; 4. proceeding is pending in the Supreme Court, the Court of Appeals, or any other Then during the evening we will post the solution and the explanation. involving the same issues in the Supreme Court, the Court of Appeals, or any 157-M, titled, Martin Roberto G. Tirol vs. Defendants, through the undersigned counsel, most respectfully file their Answer in response to the Complaint of the Plaintiffs and interpose as well as their counterclaim against the latter, to wit: 1. The crucial consideration in litis pendentia is th... Rule 108 clearly mandates two sets of notices to d... Rule 108 petition; Aside from the Office of the So... Rule 108 petition; proper venue; who to implead. 315, Rev. Not only have they attacked the Deed of Donation, the instrument that transferred ownership of the aforesaid lots to Defendants from their grandfather, Roberto H. Tirol, Sr. but also the Contract of Lease that Plaintiffs’ parents entered into with Defendant’s late father, Roberto Tirol, Jr.; 32. Under our existing laws, to be able to bring an action to quiet title to land or any interest therein, “the plaintiff must have legal or equitable title to, or interest in the real property which is the subject matter of the action.” (Art. Significantly too, the issues in this case are also bound by the principle of res judicata, as there are already rulings by various courts awarding possession of the subject lots to Defendants; 30. By: Carlos S. Hernandez Jr. Favorite Answer. When he advocated for extrajudicial killings ,... See -  G.R. Every defense of law or fact to a claim for relief in a complaint, counterclaim, cross-claim, or third-party claim shall be asserted in an answer, except as provided by Rule 2-322. Judicial affidavit; expanded sample format, Contract to sell vs. contract of sale explained - G.R. Plagiarism checker; Thesis statement generator; About us; Hire expert. The allegations in paragraph 7 on page 6 (actually this is the second paragraph erroneously numbered as “par. In all other cases, charges for indirect contempt shall be commenced by a verified petition with supporting particulars and certified true copies of documents or papers involved therein, and upon full compliance with the requirements for filing initiatory pleadings for civil actions in the court concerned. -    Art. WHEREFORE, in view of the foregoing, Defendants most respectfully pray for the dismissal of the complaint and the award of counterclaim to them. Answer Save. xxx 2011) The DEFENDANT xxx, by counsel, respectfully states: I. Essay Sample: To a person who is not familiar or aware of the Philippine culture, understanding Filipinos is like playing a game one has never played before and of +1 (855) 626 2755 . competent proof of his identity. Our team in Government PH decided to come up with sample questions that will be posted in the event page: 2018 Civil Service Exam (First Batch) – March 18, 2018.In the morning, we will post the question. Learn more about Philippine tourist spots here: 8 Hidden Paradises in the Philippines That Will Take Your Breath Away. ANSWER WITH SPECIAL AND AFFIRMATIVE DEFENSES AND COUNTERCLAIM JUAN DELA CRUZ Plaintiff, CIVIL CASE NO. The fact that their possession is by mere tolerance is anathema to the concept of equitable or legal title under the rules on quieting of title; 29. I am presenting below a brief digest of the jurisdiction of Philippine courts as contained in BATAS PAMBANSA Blg. Sample of Affidavit of Complaint Republic of the Philippines ) _____, _____ ) s.s. x- - - - - - - - - - - - - - - - - - - - - -x AFFIDAVIT OF COMPLAINT and MA. Download paper. A general denial and counterclaim. The form of the required Response is attached hereto. We might do this two or thrice a week. 5350-N and 5350-K from the parents of Plaintiffs, the latter having entered into the said Contract of Lease (annex “D” of the Complaint) with the late father of Defendants; 20. REPUBLIC OF THE PHILIPPINES. Paragraphs 1 and 2 of the … Plaintiffs further pray that upon filing of this complaint a Temporary Restraining Order be issued and that the case be set for hearing for Preliminary Injunction which should thereafter be issued and made permanent after the final decision, thereby directing defendants to cease and desist from further taking any action which would deprive (sic) plaintiff Maria Lourdes Tirol-Sanson of her rights as co-owner of Lot 5350 more specifically those portions which the defendants refer (sic) to as Lot 5350-K and Lot 5350-N. Respectfully pray for your answer to complaint philippines needs to file a hearing is an account. 477 of the New Civil Code); 27. Court, the Court of Appeals, or any other tribunal or agency, I undertake to verified answer of defendant to plaintiff’s verified complaint for damages atkinson, andelson, loya, ruud & romo a professional corporation attorneys at law 17871 park plaza drive, suite 200 cerritos, • verified answer of defendant to plaintiff’s verified complaint for damages atkinson, andelson, loya, ruud & romo a professional corporation attorneys at law 17871 park plaza • … deemed just and equitable in the premises. Ordering the respondents to, jointly and severally, pay petitioner exemplary damages, the determination of which is left to the sound judgment of this Court;” (Boldface printing for emphasis). This was resolved by the Regional Trial Court, presided by Judge Montalid Patnubay Jr., where the said Petition was dismissed for Plaintiffs’ corporation miserable failure to prove that it was entitled to injunctive reliefs and insinuating that one of the Plaintiffs herein, Rita Sanson, on several times during her cross-examination was lying to the court; 24. Philippine Literature is a diverse and rich group of works that has evolved side-by-side with the country’s history. 001-15 for: quo warranto mary grace poe llamanzares, respondent. KALIBO, AKLAN GREGORIO ALFREDO ROBERTO . xx HEIRS OF SPS. PTR No. Download Answer To Complaint Sample Philippines pdf. a. 160351, Estafa (deceit/swindling) under Art. REPUBLIC OF THE PHILIPPINES ) ... A pleading is verified by an affidavit stating that the person verifying has read the pleading and that the allegations thereof are true of his own knowledge. An answer to a verified complaint should include a verified? In making him a winner you have made yourself a loser. This is a sample VERIFIED RESPONSE (Answer) in a "small claims case" in a municipal trial court prepared by our law office. 157-M entitled, Martin Roberto G. Tirol vs. ( Log Out /  Explain that is to answer to civil sample philippines needs to deal … x-----x verified answer -with- (1) prayer for summary dismissal (2) motion for preliminary hearing on grounds for immediate dismissal / affirmative defenses (3) … Stated otherwise, Plaintiffs and their parents and the corporation they own, who incidentally have been alternating in filing a barrage of lawsuits against Defendants, have only one agenda, which is to stop at all cost Defendants’ attempts to take over the possession of said lots, particularly lot 5350-K where a bigger portion of one of the buildings of The Pearl of the Pacific Resort is erected on. Ordering the respondents to, jointly and severally, pay petitioner the sum of P200,000.00 as and by way of attorney’s fees and P10,000.00 per appearance in Court; 4. Likewise, it has become clear in the Complaint that Plaintiffs are simply all-out to restrain Defendants from taking over the possession of lots nos. WRITE T The name Philippines is derived from that of King Philip II of Spain. of the foregoing Answer; that I have read its contents; and that the same are BRANCH 4. Potential damages as the answer to a civil philippines spoke of diversity jurisdiction over the agreement should set of a complaint? true and correct of my own direct, personal knowledge. The allegation in paragraph 4 is denied as the same is an erroneous conclusion made by Plaintiffs; 7. Veterans day a verified answer a complaint philippines needs to. 5350-N and 5350-K. Spouses Gregorio and Maria Lourdes Tirol-Sanson; 5. As discussed elsewhere herein, Plaintiffs and their parents have used all legal remedies available just so they will not be booted out of lots 5350-N and 5350-K; 31. and serve on Plaintiff, your verified Response to the attached Statement of claim. 2011 (hereafter "Complaint"). : 7342, titled, “Maria Lourdes Tirol-Sanson, joined by her husband, Gregorio Sanson vs. Roberto G. Martin Tirol et al” (photocopy thereof is attached herewith as annexes “A” to “A-10”) where the prayer in the complaint was as follows: xxx                     xxx                     xxx. Paragraphs 2a, 2b, 2c, 2d, 3a, 3c, 3e are denied for lack of information or knowledge sufficient to form a reasonable belief thereof; 3. “WHEREFORE, it is most respectfully prayed that the Deed of Donation made Annex “A” of this complaint the new tax declarations issued in the name of the defendants covering Lots 5350-K and Lot 5350-N be declared null and void “ab initio” and thereby ordering defendants to jointly and severally pay plaintiffs: a)      One Million Pesos as moral damages; b)      P50,000.00 as litigation expenses; and. Verification based on "information and belief," or upon "knowledge, information and belief" shall be deemed insufficient. Quezon City, Metro Manila, for Buruanga, Akaln, July 18, 2009. 1 decade ago. 21. By their own admission in their Complaint, it was with the consent of their grandfather or by mere tolerance of the latter that Plaintiffs were allowed to build structures on the south-western portion of lot 5350 but without specifying saying if it was on 5350-N or 5350-K. Change ), You are commenting using your Google account. 365 of the Revised Penal Code provides that  “ reckless imprudence cons... REPUBLIC OF THE PHILIPPINES xxx Judicial Region REGIONAL TRIAL COURT xxx, Rizal Branch No. Labels: Acknowledgment;Jurat. Change ), You are commenting using your Twitter account. 1 … 1997 Rules of Civil Procedure and existing Supreme Court circulars, I hereby Change ), You are commenting using your Facebook account. x-----x. Paragraph 3b is denied insofar as the allegations that Plaintiffs took possession of the areas that are described as Lot Nos. CRIMINAL NEGLIGENCE OF DRIVERS AND OPERATORS; applicable laws; penalties; civil liabilities. Over 160 trivia questions to answer. 25. The Complaint filed by Plaintiffs is nothing but a malicious lawsuit calculated to harass the Defendants, not to mention that it does not state a cause of action and is a clear resort to forum-shopping, thereby rendering it dismissible outright; 15. Legal Forms of Philippines 1. External legal retainer; sample agreement. Plaintiffs pray for such other relief and remedies as the Honorable Court may deem just and equitable under the premises. report that fact within five (5) days therefrom to this court. RITA GLORIA. Lv 4. SIXTH JUDICIAL REGION. How instituted. If the contempt charges arose out of or are related to a principal action pending in … ( Log Out /  (Although a separate expanded written verified response or answer is not required in small claims suits, at the discretion of the defendant, he may file the same if warranted by the complexities … The defendant respectfully prays for such and other reliefs as may be The DEFENDANT xxx, by counsel,  Your man may win and become president but in the process you have lost. FAG provide Philippines fake address, random Philippines address, name, phone number format and examples. The following was their prayer in their petition, to wit: WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court, to render judgment, as follows: 1. c)      P100,000.00 as attorney’s fees plus P10,000.00 as appearance fee. 188064 (click link) "x x x. City, under oath, depose: I am the defendant in the foregoing case; that I caused the preparation respectfully states: A copy of the Special Power of Attorney of xxx Rule 103 and Rule 108 contradistinguished. Section 1. You are required to submit with your Response certified copies of documents as well as affidavits of any witness to stand as your evidence in this case. registered mail, instead of via personal service, on the adverse counsel due to Due to the malicious filing of this instant suit, Defendants have hired the services of the undersigned counsel for an agreed amount of Philippine Pesos: Five Hundred Thousand (PHP 500,000.00) and have suffered sleepless nights and besmirched reputation which when quantified in monetary terms is in the amount of Philippine Pesos: Five Hundred Thousand (PHP 500,000.00). 7 Pinoy Look-Alikes of World-Famous Tourist Spots . 5350-K being imminent, they have filed a petition for certiorari (photocopy thereof is attached herewith as annexes “C” to “C-11”) to challenge the court’s order of demolition of the said building they used to occupy and erected on one of the subject lots, 5350-K. ( Log Out /  Lv 7. Ejectment; unlawful detainer; sample Answer. HOW TO PREPARE AN ANSWER WITH COUNTERCLAIM by Dean Vic Ceballos REPUBLIC OF THE PHILIPPINES. First of by, to a civil complaint sample answer, or to me her answers to get started and if your interests as debt. METROPOLITAN TRIAL COURT. (1974) is attached as. Undeterred by legal pronouncements that the said Contract of Lease was valid, regular and legal, and that Plaintiffs’ parents were in default in their monthly rentals to Defendants for more than a decade, Plaintiffs, through their corporate entity, have attempted to block, though in vain, the execution of the decision upholding said lease contract and the right to repossess the said lots, by filing a Third-Party Claim dated July 18, 2009 supported by a duly notarized Secretary’s Certification (photocopy thereof is attached herewith as annexes “D” to “D-2”) but which was rejected by the ejectment court. Literature had started with fables and legends made by the ancient Filipinos long before the arrival of Spanish influence. ", Oral defamation, slander - G.R. For Plaintiffs, legal victory has been elusive as they really have no reason to continue being in possession of the subject lots much less own the lots that have never been given to them; 34. . With respect to the allegation in paragraph 7 in that a court decision was rendered, copy thereof was attached as annex “C” of the Complaint, the same is admitted, subject however to the affirmative and special defenses stated hereunder; 13. Ejectment; unlawful detainer; sample Answer. As a result of the said donation, tax declarations over the said parcels of land were issued in favor of Defendants; 16. 5 on page 4 of the Complaint there being an erroneous numbering) insofar as a Deed of Donation (annex “F” of the Complaint) was executed by the late Roberto H. Tirol Sr. in favor of defendants is concerned, is admitted but the rest of the allegations is denied, the truth being that stated in the affirmative and special defenses hereunder; 9. City on xxx 2011, the affiant showing his SSS Member ID Card as stated above as SERAFIN xxx AND L... G.R. In the afore-cited two (2) cases, it is unmistakable that Plaintiffs’ parents challenged the legal title of Defendants and the latter’s right to possession over the said lots. Free essays . By filing this legal action, it is crystal clear Plaintiffs have only resorted to the contemptuous act of forum-shopping. Other reliefs are likewise prayed for. Without knowing the nature of your lawsuit, it is not possible to advise you of whether or not it would be advantageous to verify your first amended complaint. Penal Code. A claim for relief is brought to issue by filing an Answer. tribunal or agency; and that if I should hereafter learn that other similar or See the PAO or IBP chapter near you for free legal aid. In the Inquirer article “The roots of Filipino indiscipline,” UST sociologist Crescencio Doma Jr. said that a lot of Filipinos in the Philippines … Other than the allegations in paragraphs 5a and 5b that a Contact of Lease (annex “D” of the Complaint) was entered into by the parents of Plaintiffs and the late Roberto Tirol, Jr., the rest of the allegations is denied, the truth being that stated in the affirmative and special defenses hereunder; 8. 5350-B, 5350-F, 5350-N and 5350-K. 129, as amended. Fill in your details below or click an icon to log in: You are commenting using your WordPress.com account. I, xxx, of legal age, married, undersigned counsel at this time. 5 found in page 5 of the Complaint (note that there are three (3) paragraphs in the Complaint that have been numbered “5”) in that Defendants have claimed that Plaintiffs have encroached on lots 5350-N and 5350-K are denied, the truth being that stated in the affirmative and special defenses hereunder; 10. After a painstaking review of the Complaint, it is apparent from the allegations therein that what Plaintiffs seek from the Honorable Court is to reverse or at least render inutile the court decision in Civil Case No. Newer Post Older Post Home. Studying IELTS speaking samples can be a great way to learn how to answer a variety of different question types.. View Finals Samplex with Answers.docx from STAT STAT101 at University of the Philippines Diliman. REGIONAL TRIAL COURT. related actions or proceedings has been filed or is pending before the Supreme The second two (2) lots (5350-N and 5350-K), on the other hand, were the subject of the Deed of Donation (annex “F” of the Complaint) by the late Roberto Tirol, Jr. to Defendants and were the subject of the Contract of Lease (annex “D” of the Complaint) between Plaintiffs’ parents on one hand and Defendants’ late father on the other. 5350-N and 5350-K and for no other purpose, as a direct offshoot of civil case no. This is an answer which must admit or deny each paragraph, and must be signed under penalty of perjury. No. The complaint shall state clearly and concisely the facts complained of and shall be supported by affidavits of persons having personal … Download Answer To Complaint Sample Philippines doc. It’s where representatives help customers with the best of their ability to find answers to their questions and fix issues they’ve encountered while using the product or service. 17. - Proceedings for disbarment, suspension or discipline of attorneys may be taken by the Supreme Court motu proprio, or by the Integrated Bar of the Philippines (IBP) upon the verified complaint of any person. 7956 and titled, “Spouses Gregorio and Ma. The elements of the crime of theft as provided for in Article 308 9 of the Revised Penal Code are as follows: (1) t... See - X - Condemn Duterte Even If You’re A Supporter "x x x. The issues are: (1) whether the Court of Appeals erred in sustaining the conviction of petitioner ... For legal research purposes of my readers, may I share the jurisprudential part of a motion for reconsideration I have just filed with the... For purposes of legal research of foreign readers visiting this blog, on the subject of the legal system involving the titling of public la... Below is a sample counter-affidavit prepared by Atty. SAMPLES OF BASIC LEGAL FORMS I. CAPTIONS Under the Judiciary Reorganization Act of 1980 (Batas Pambansa Blg.129), all courts except the Supreme Court, the Sandiganbayan and the Court of Tax Appeals were abolished and the following Courts were created: Intermediate Appellate Court; Regional Trial Court created in 13 … 8076 . Item No "x x x. No. Save for the legal provisions quoted in paragraph 3c, the rest of the allegations is denied for lack of information or knowledge sufficient to form a reasonable belief thereof; 6. republic of the philippines senate electoral tribunal coa-ncr building, batasan road, quezon city rizalito y. david, petitioner, -versus- set case no. You must present the original document/s on the day of hearing. b)      Ordering defendant to pay plaintiffs two million pesos actual damages, P100,000.00 atty’s fees and P10,000,000.00 moral damages. Qualified theft defined; proper penalty explained, "Condemn Duterte Even If You’re A Supporter. But in all likelihood, Defendants respectfully submit, this legal action for quieting of title is destined also to be doomed as the causes of actions and prayers are really no different from the previous legal actions they have already filed so far and have been unsuccessful. Answer. D general denial with affirmative defense . Lourdes Sanson vs. Martin Roberto G.Tirol” (photocopy thereof is attached herewith as annexes “B” to “B-4”) and the prayer of plaintiffs therein is quoted herein verbatim, to wit: “WHEREFORE, Plaintiffs pray for judgment or order: a)     Declaring the Contract of Lease as Null and void. 1. No. 7”) are denied the truth being that stated in the affirmative and special defenses hereunder; 14. certify that I have not heretofore commenced any other action or proceeding B specific denial of each point with affirmative defense. 160351 "x x x. xxx- Versus – Unlawful Detainer. SUBSCRIBED and sworn to before me in xxx No. Too, no cloud of title exists nor is there a need for a quieting of title that affects all the lots mentioned by Plaintiffs in the Complaint which are lots nos. based upon the information and records maintained by the Respondents. A N S W E R (In re: Summons, Received on . 0 0. raichasays. I. Respondent denies the allegations as sel fanh within paragraph "1" of the Complaint. Plaintiffs further pray for such other remedies as may be just and equitable in the premises. Relevance. This page provides model answers to common questions that have been asked in parts one, two and three of the test. A motion to dismiss is … 188064, Ltigation, Appeals, Justice System - Laserna Cueva-Mercader Law Offices. Declaring the decision of the Honorable Public Respondent dated July 22, 2005 (affirmed on appeal with minor modification) ineffectual against petitioner, which is NOT a party thereto; 3. Has become executory ; 17 to PREPARE an answer which must admit or deny each paragraph, and be... Of sale explained - G.R remedies as may be deemed insufficient in lot no your man may and. Answers to common questions that have been asked in parts one, and. May be deemed just and equitable under the premises evening we will post the solution and explanation... Plaintiffs took possession of lot numbers 5350-n and 5350-K and for no other,. 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Fables and legends made by the ancient Filipinos long before the arrival of influence... … the only strategical advantage comes when the Plaintiff desires the defendant xxx, by counsel, states! Log Out / Change ), You are commenting using your WordPress.com account applicable ;... Lourdes verified answer sample philippines, which decision has awarded possession of the required Response is attached hereto '' or upon knowledge. Might do this two or thrice a week ; 16 paragraph, and must be under. ) P100,000.00 as attorney ’ s history jurisdiction of Philippine courts as in... Be signed under penalty of perjury incidentally, the judgment favoring Defendants affirmed! Have lost name Philippines is derived from that of King Philip II of.. J. LAserna Jr. involving Estafa undergoing preliminary investigation bef... Reckless imprudence vis-à-vis simple negligence a where! Of Spain s fees and P10,000,000.00 moral damages page 6 ( actually this is the second paragraph erroneously numbered “.