Republic of the Philippines

Regional Trial Court

NATIONAL CAPITAL JUDICIAL REGION
BRANCH 28, MANILA

FROG PRINCE, CIVIL CASE No. 12-345678

Plaintiff,

-versus— for:SPECIFIC PERFORMANCE

PRINCESS TIANA,
Defendant.
x- - - - - -x

ANSWER

COMES NOW, Defendant, through the undersigned

counsel and unto this Honorable Court, most
respectfully avers:

1. Defendant
admits the averment in paragraph 1 of
the complaint as it refers to personal circumstances of
both the Plaintiff and the Defendant;

2. Defendant admits the allegations in paragraphs

2;

3. Defendant denies paragraphs 3 and 4 of the

complaint. The truth of the matter is discussed in the
Defendant’s affirmative defenses.

By way of affirmative defense:

a. That the parties agreed orally to novate the

contract;

b. That
the Plaintiff agreed to be paid instead of
obliging the Defendant to kiss him;

c. That
the Plaintiff had already been paid for the
amount of fifty thousand pesos (Ph50,000.00)as
evidenced by the Acknowledgment Receipt hereto attach
as “Annex 1” and made an integral part hereof;
 d. Thatif Defendant will be forced to comply the
novated contract tantamount to violation of her
constitutional right against involuntary servitude.

By way of counterclaim, Defendant alleges:

That by reason of filing this baseless and

malicious suit, Defendant suffered sleepless night and
serious anxiety, to which she should be entitled to
moral damages in the amount of Ph50, 000.00 and
reimbursement of Attorney’s fee of Ph25, 000.00 as well
as exemplary damages as may be determined by this
honorable Court, to discourage Plaintiff and other
similarly inclines from baseless suit like the
Complaint herein.

PRAYER
WHEREFORE, premises considered, Defendant
respectfully prays unto this honorable Court to dismiss
the case based on the foregoing grounds and for utter
lack of merit. Plaintiff should pay Defendant the
amount of Ph50, 000.00 moral damages, Ph25, 000.00 for
reimbursement of Attorney’s fee, Ph25, 000.00 for
reimbursement of litigation expenses, and exemplary
damages as may be determined by this Honorable Court.

Other equitable reliefs are likewise prayed for.

July 28, 2017. City of Manila, Metro Manila,

Philippines.

DISNEY LAW OFFICE

Counsel for the Defendant
Disneyland Tower 2, Ermita, Manila

By:

ELGIERAYDOLPH Y. BUISON
Roll No. 98765
IBP No, 55555/12-31-2018/Manila
PTR No. 98765/12-31-2018/Manila
Republic of the Philippines )
City of Manila, Metro Manila )ss

VERIFICATION AND CERTIFICATION

I, PRINCESS TIANA, of legal age, Filipino citizen,

single and resident of 144 River Valley, Fairytale Kingdom, Manila, Metro Manila,
Philippines, after having duly sworn to in accordance with
law, do hereby depose and say:

1. That I am the Defendant in the above-entitled

case, and I have caused the preparation of the
foregoing Answer and have read and understood the
allegations contained therein;

2. That
all allegations in said Answer are true and
correct based on my own personal knowledge and based on
authentic documents and records.

IN WITNESS WHEREOF, I have hereunto set my hand and

affixed my signature this 27th day of July, 2017 in the
City of Manila, Metro Manila, Philippines.

PRINCESS TIANA
Affiant

SUBSCRIBED AND SWORN TO before me this 27th day of

July 2017, in the City of Manila, affiant personally
appeared exhibiting to me her competent proof of
identity indicated above her name.

Doc. No. _______; MARY GRACE E. TABUZO

Page No. _______; Notary Public
Book No. _______; Until December 31, 2017
SERIES OF 2017. IBP No. 1234567/January 5, 2015
PTR No. 7654321/January 5, 2015
Roll No. 56789
MCLE No. V-00000123

Copy furnished:
 MIKHAEL ANDREI F. LARIOS
Counsel for the Plaintiff
Magaling Law office
2nd Floor ABC Building, Sampaloc, Manila

EXPLANATION

Copy of the foregoing ANSWER was served to

plaintiff’s counsel by registered mail due to time and
distance constraints and for lack of the undersigned’s
staff who can serve the same in person.

ELGIERAYDOLPH Y. BUISON