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CARLOS R. CALINOG,
Defendant.
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ANSWER
1. Paragraphs one (1) and two (2) of the Complaint are admitted;
2. Paragraphs three (3) to five (5) of the Complaint are denied for lack
of knowledge or information sufficient to form a belief as to the
veracity or falsity thereof, the allegations therein being matters
known only to and are within the control only of the plaintiff;
1. On May 25, 2015, the Defendant and the Plaintiff did not see each
other because the former was having a vacation in Baguio City as
evidenced by the photocopy of entry/exit of vehicles monitoring
sheet, attached herein, marked as Annex A, and made an integral
part hereto. Such monitoring sheet is issued by the Gate Security
Department of the Subdivision where the Defendant resides.
2. The Plaintiff never gave the defendant the alleged amount of Three
Hundred Fifty Thousand Pesos (350,000.00); that Defendant did
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Answer
not sign the alleged promissory note; and that Defendants
signature is forged.
COMPULSARY COUNTERCLAIM
PRAYER
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Answer
LOVELY ANGEL LAI
Roll of Attorney No. 0000
PTR No. xxxx; 01-02-01 / Iloilo
IBP Member Roll No. 00000/07-08-01 / Iloilo
MCLE Compliance No. Ix021xxxxxxx / 12-10-01
Doc. No.: 49
Page No.: 8
Book No.: II
Series of 2015
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Answer