Republic of the Philippines

Regional Trial Court

Branch 34, Iloilo City
Winnilyn J. Mooc,
Plaintiff,
Civil Case No. 0000028
For: Sum of Money

-versusMark J. Sancho,
Defendant,
x---------------------------------------x
ANSWER
DEFENDANT, by counsel, respectfully states that:
Admissions/Denials

1. He admits the contents of paragraph 2 only insofar as his personal liability to the
principal amount of THREE HUNDRED THOUSAND PESOS (Php300,000.00)
evidenced by the executed Acknowledgment of Debt but specifically denies the contents
of said document insofar as the stipulation of the interest for the reason stated in the
Affirmative Defense below.
2. He admits the contents of paragraphs 3 to 4.
3. He specifically denies the contents of paragraph 5 for the reason stated in the Affirmative
Defense below.
Affirmative Defense
4. Defendant reiterates, repleads and incorporates by reference all the foregoing insofar as
they are material and additionally submit that the Complaint should be amended because
the Complaint fails to state that no stipulation of interest was agreed upon and the written
value of 5% was handwritten only by the Plaintiff and by the Plaintiff alone.
WHEREFORE, Defendant respectfully prays that judgment be rendered in his favour by
amending the Complaint and granting defendants claim that only the principal amount of
THREE HUNDRED THOUSAND PESOS (Php300,000.00) be awarded to the plaintiff.
Other just and equitable relief are prayed for.
Iloilo City; 11 November 2015.
JOEY B. MONDERO
Counsel for Defendant
Mondero Law Office
Hillside Bldg. Quezon St. Iloilo City 5000
IBP No. 561125 / May 4, 2016
PTR No. 2154897 / January 12, 2015
MCLE No. 51689 / June 15, 2015

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING

I, Mark J. Sancho, of legal age, do hereby state that: I am the defendant in the case filed
by Winnilyn J. Mooc for sum of money; in response, I have caused the preparation of this
Answer; I have read its contents and affirm that they are true and correct to the best of my own
personal knowledge; I specifically deny the genuineness and due execution as well as the
binding effect of the stipulated interest in the documents pleaded by plaintiff; I hereby
certify that there is no other case commenced or pending before any court involving the same
parties and the same issue and that, should I learn of such a case, I shall notify the court within
five (5) days from my notice.
IN WITNESS WHEREOF, I have signed this instrument on 11 November 2015.

MARK J. SANCHO

SUBSCRIBED AND SWORN to before me this ______ day of ______________ 200_____ at

____________________ affiant exhibiting to me his Community Tax Certificate No. 894512
issued on January 12, 2015 at Iloilo City.

Doc. No. _____;

Page No. _____;
Book No. ______;
Series of 2015