Answer with Cross-claim Sample

REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Manila

Branch 1

XIAN LAO,
Plaintiff,

-versus-

CIVIL CASE No. 12345

MATEO GO,
Defendant.
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ANSWER WITH CROSS-CLAIM

COMES NOW, the defendant, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:
1.That he ADMITS paragraph 2 of the complaint;
2.That he DENIES paragraph 3 of the complaint, the truth being that it was the defendant
JOLO TREVOR who applied for and exclusively benefited from the loan with the plaintiff,
answering defendant acting as mere co-signer in the promissory note to accommodate
defendant TREVOR and to guarantee the loan;

3.That he lacks knowledge or information sufficient to form a belief as to the truth of the
allegations contained inparagraphs 3, 4, and 5 of the complaint and therefore, specifically
DENIES the same;

SPECIAL/AFFIRMATIVE DEFENSES

4. That without the knowledge and consent of answering defendant, the principal
condition of the loan was changed and the term of payment thereof was unreasonably
extended by the plaintiff, to the prejudice of answering defendant;

5. That there was undue delay on the part of the plaintiff in enforcing the payment of
the obligation, and the loan could have been paid immediately at maturity had there been
prompt and timely notification to answering defendant of the non-payment of the loan by
defendant TREVOR;

CROSS-CLAIM AGAINST HIS CO-DEFENDANT

6. That defendant TREVOR should reimburse answering defendant on any and whatever
amount the latter may be held answerable or which he may be ordered or suffered to pay
under and by virtue of the present action in favor of the plaintiff, answering defendant not
having benefited whatsoever from the loan which defendant TREVOR obtained from the
plaintiff;

7. That defendant TREVOR should pay plaintiff directly and fully on the amounts claimed
by the latter in its complain he having benefited directly and exclusively from the
transaction alleged in the complaint;

WHEREFORE, premises considered, answering defendant respectfully prays to the

Honorable Court to render judgment as follows:
1.By dismissing the complaint against answering defendant;
2.By ordering defendant TREVOR to pay directly and fully to the plaintiff the amounts
claimed by the latter in the complaint;
3.By ordering defendant TREVOR to pay answering defendant for any and whatever
amounts the latter may be held liable to or be ordered or suffered to pay plaintiff under
and by virtue of the plaintiffs claim in the present action.
Answering defendant prays such other relief and remedies as may be deemed just
and equitable under the premises.

City of Manila, October 1, 2012.