REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

Branch 8
Quezon City
MOCHA USAN,
Plaintiff,

-versus- CRIMINAL CASE NO. 123

For: Libel
ALMA MORENA,
Defendant.
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ANSWER

COMES NOW, the defendant, through the undersigned counsel and unto this Honorable Court, most
respectfully avers:

1. That she ADMITS the contents of paragraph 7 of the complaint only insofar as the italicized text was
published in Balita Ngayon last March 30, 2017;
2. That she ADMITS the truthfulness of the complainant's recollection of facts regarding only the complainant's
rejection of her proposal in paragraph 5 of the complaint, but DENY the insinuation of motive in paragraph 6
that the article in question was prompted by such rejection as to deduce intent to malign the plaintiff;
3. That defendant caused the publishing of a mere statement of opinion and that the statement complained of
indicated a legitimate basis for forming such opinion;
4. That an honest person could have held that opinion, as the defendant indeed held such opinion, based on
facts which existed at the time the statement was made;
5. That the defendant's statement is on a matter of public interest;
6. That the defendant caused its publication, not as a malicious act to malign the plaintiff's character, but with
reasonable belief, that publishing the statement was in the public interest.

WHEREFORE, the defendant respectfully prays that the complaint be dismissed with costs against the
plaintiff.

Other relief and remedies as may be deemed just and equitable.

Quezon City, Philippines, this 15th of May 2017.

ARQUILLO ROMERO SUMANGA LAW OFFICES

Counsel for the Defendant
Units 405-410, Fort Legend Tower, 32nd St cor. 3rd Avenue
Bonifacio Global City, Taguig City

By:
ATTY. GERTRUDE ARQUILLO
Roll No: 69689
IBP No. 19805/1-5-2013/Manila
PTR No.15893
Copy furnished:
MAGAGANDANG ATTORNEYS
Counsel for the Plaintiff
Rm. 88 3/F BGC Taguig