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Province of Iloilo
MUNICIPAL TRIAL COURT OF DUMANGAS
Dumangas, Iloilo
___________________
Plaintif,
-versus__________________
Defendant.
x------------------------------------------x
latter
being
one
of
the
descendants
of
the
registered
owner
AFFIRMATIVE DEFENSES
12. That plaintiff has no right to eject the defendant since the latter as
a co-owner of the property has all the legal right to stay thereon;
13. That whatever ownership right or title the plaintiff has over the
property as a whole is a sham and not recognized by majority of the coowners
considering
that
plaintiff's
title
was
derived
by
employing
COUNTERCLAIM
14. That by reason of the unwarranted filing of the present complaint,
defendant was constrained to hire the services of counsel and obliged to pay
attorney's fees in the amount of Php 20,000.00 which plaintiff should
reimburse.
15. That likewise the herein defendant was unnecessarily dragged into
litigation and obliged to meet expenses of litigation in the amount of not less
than Php 10,000.00 which plaintiff should reimburse;
PRAYER
WHEREFORE, it is most respectfully prayed that judgment be rendered
in favor of the defendant and against the plaintiff thereby dismissing the
complaint and granting the counterclaim thereby ordering plaintiff to pay
defendant the following:
a) Php 20,000.00 as attorneys fees; and
b) Php 10,000.00 as litigation expenses.
Defendant prays for such other relief and remedies as the Honorable
Court may deem just and equitable under the premises.
Iloilo City for Dumangas, Iloilo, Philippines, March 12, 2013.
NAME OF LW FIRM
Counsels for Respondent-Appellant
ADRESS
E-mail address: ipptlaw2002@hotmail.com
Tel. No. (033) 3371154 & (033) 3371146
By:
NAME OF LAWYER
IBP NO. ___________/ Jan. 2, 2014 / ILOILO CITY
PTR NO. ___________/Jan. 3, 2014/ ILOILO CITY
ATTORNEYS ROLL NO. _________
MCLE COMPLIANCE NO. IV-0005183/03/20/12
Copy furnished:
Atty. Douglas Edwin Del Rosario
Counsel for Plaintiffs
Del Rosario Law Office
Door 1, Del Rosario Building
16 Libertad St., Jaro, Iloilo City
__________________________
Date:
EXPLANATION
(Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure)
Personal service cannot be effected upon Atty. Douglas Edwin Del
Rosario at Del Rosario Law Office, Door 1, Del Rosario Building 16 Libertad
St., Jaro, Iloilo City due to the distance between the said address and the
office of the undersigned counsels hence copy of this Answer with
Counterclaim is being served upon him through registered mail with return
card.
COUNSEL