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JUAN JAMERO,
Defendant
X-------------------------------------X
ANSWER
3. Paragraphs three (3) and four (4) of the complaint is denied insofar as
it alleges that the defendant has not made any payment and as of December
10, 2016, the total amount due is one million pesos (PHP 1,000,000.00), with
an accrued interest of thirty thousand pesos (PHP 30,000.00) as stated
therein, the truth being alleged in the special and affirmative defenses part
herein below.
COMPULSARY COUNTERCLAIM
PRAYER
Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.
3. I have read the contents thereof and the facts stated therein are true and
correct to my personal knowledge and/or on the basis of documents and
records in my possession;
________________________
JUAN JAMERO
Affiant
TIN 49932-442; Iloilo City
ACKNOWLEDGMENT
all known to me to be the same person who executed the foregoing instrument
and hereby acknowledged to me that the same is their free and voluntary act
and deed.