Republic of the Philippines

REGIONAL TRIAL COURT 9TH JUDICIAL REGION Branch ____ Zamboanga City
THE VJD LENDING INVESTOR ZAMBOANGA INC., herein Represented by its Manager May Ann J. Ekeena, Plaintiff, -versusCivil Case No. __________ For: SUM OF MONEY BABY GIRL C. ASUCARERA, BABY BOY D. DE SALINAS, and JESUS QUEMA CARBON DE PAYA, Defendants, x- - - - - - - - - - - - - -x

R E P L Y
COMES NOW, Plaintiff, unto this Honorable Court, most

respectfully manifest that on March 25, 2013, she received a copy of the Reply of Defendant BABY GIL C. ASUCARERA in the above-entitled case, and by way of a REPLY to new matters

alleged therein hereby state and thus: 1. That plaintiff denies and controverts the allegation in paragraph 4 of the ANSWER concerning the true amount of the loan, the best evidence concerning the same being the Promissory Note attached to the complaint; 2. That contrary to the allegations of the defendant, the actual amount of the loan was P500,000.00 and not

P50,000.00. The Promissory Note attached as Annex 1Asucarera et seq. is a clear alteration of the true amount of P500,000.00; 3. That it is not true that defendants made payments of any amount of the loan and much less that said payments

exceeded the actual amount P20,000.00;

2 4. That contrary to the allegations of the defendant, her obligation has not prescribed because repeated demands have been made upon her within the prescriptive period; 5. That neither is it true that the said obligation has been extinguished by compensation. The truth of the matter is that while plaintiff indeed bought a parcel of land from defendant, the purchase price thereof was completely and fully paid and satisfied as acknowledged by the

defendant-seller in the deed of absolute sale; Respectfully submitted. City of Zamboanga, Philippines, February 14, 2013. VEEJAY D. RAFAELA Counsel for the Defendant No. 025, Canelar Street, Zamboanga City PTR No. 0202234; Jan. 08, 2013/ZC IBP OR No. 111755849; Jan. 09, 2013/ZC MCLE Compliance Number 11120015418 Roll No 3832212. Republic of the Philippines) CITY OF ZAMBOANGA. . . . . ) S.S. x- - - - - - - - - - - - - x VERIFICATION I, MAY ANN J. EKEENA, of legal age, single, and with address at 143-C Divisoria, Zamboanga City, after having been sworn in accordance with law, hereby depose and say: That I am the representative of the plaintiff VJD Lending Investor Zamboanga Inc., in the above-entitled case as duly authorized by its Board of Trustees; that I have caused the foregoing REPLY to be prepared; that I have read and understood the contents of the same; ad that the allegations therein are true and correct based on my own knowledge and authentic documents; IN WITNESS WHEREOF, I have hereunto set my hand on this ___ day of March 2013 in the City of Zamboanga, Philippines. MAY ANN J. EKEENA Affiant
SUBSCRIBED AND SWORN to before me on this ___ day of March 2013 in the City of Zamboanga, Philippines.

VANESSA JOY RAFAELA DELATADO Notary Public Until December 31, 2014 Zamboanga City PTR No. 020931; Jan. 07, 2013/ZC BP OR No. 755849; Jan. 09, 2013/ZC
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