REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch 56
QUEZON CITY

SPOUSES JOSEFINA
RAMOS and MR.
RAMOS​,
Plaintiffs​,

CIVIL CASE No. 6578989

FOR: Collection of Sum of
Money
-​versus​-

SPOUSES DR. MARIE

CARLOS and MR.
CARLOS​,
Defendants​.

x----------------------------------------------------------------x

ANSWER

COMES NOW, the Defendants, through the undersigned

counsel and unto this Honorable Court, most respectfully
states the following in response to the Complaint for
Collection of Sum of Money:

1. An order dated 25 September 2019 to file an Answer

for the Complaint for Collection of Sum of Money was
received by Defendants on 5 October 2019;

2. Filing of this Answer is within the reglementary period

to file an answer;

3. Paragraph 2 of the Complaint is admitted insofar as

Defendants’ personal circumstances;

4. Paragraphs 4 to 6 are admitted insofar as to the due

execution of the Promissory Note by Respondents and
Petitioners;
 5. Paragraphs 7 to 17 are denied in their whole totality
for being false. Being the truth of the matter is that
Respondents were able to pay their obligation in the
Promissory Note on time by transferring the amount in
the said instrument in Mr. Ramos’ Bank Account;

6. A copy of the said deposit slip is attached hereto as

ANNEX “1” and made an integral part hereof;

7. In consequence to the negligence of the Plaintiffs of

filling a case which fails to show a cause of action due
to the extinguishment of the obligation, the Defendants
were able to experience sleepless nights, undue
harassment, and besmirched reputation.

PRAYER

WHEREFORE​, with the abovementioned premises

considered, it is respectfully prayed upon this Honorable
Court that, after the hearing, judgment be rendered
ordering:

1. The dismissal of the complaint for failure to show a

cause of action against Defendants due to the
extinguishment of the obligation;

2. Payment of moral damages amounting to PhP 50,000;

3. To pay attorney’s fees equivalent to Ten Percent (10%)

of the total amount claimed;

4. To pay the cost of litigation and other fees;

5. Other reliefs, just and equitable, are likewise prayed

for.

Makati City for Quezon City, Philippines, 16 October 2019.

 By:

ZAFRANCO AND ASSOCIATES LAW OFFICE

Counsel for Plaintiff
48​ Flr, RCBC Plaza, Ayala Ave.,
th​

Makati City, Philippines

Through:

ATTY. HERACLEO ROSS P. ZAFRANCO

Roll No. 11303
IBP No. 21222/06-21-21/RIZAL
PTR No. 84560/06-22-21/RIZAL
MCLE Compliance No. Z-2493592
Email

Copy furnished:
Plaintiffs
Counsel of Plaintiffs
VERIFICATION AND CERTIFICATION AGAINST FORUM
SHOPPING

I, JOSEFINA RAMOS, of legal age, do hereby state that

I am the Plaintiff in this case; I have read its contents and
affirm that they are true and correct to the best of my own
personal knowledge; I hereby certify that there is no other
case commenced or pending before any court involving the
same parties and the same issue and that, should I learn of
such a case, I shall notify the court within five (5) days from
my notice.

IN WITNESS WHEREOF, I have signed this instrument

on 21 June 2019.

JOSEFINA RAMOS
Affiant

SUBSCRIBED AND SWORN TO before me in the City of

Quezon on this day of 21 August 2019, affiant exhibiting
before me his community tax certificate no. 123415263
issued on January 2019 at Quezon City.

Notary Public
Until 25 January 2020
PTR No. 748596
Issued at Quezon City
On 25 January 2019

Doc. No. 89
Page No. 14
Book No. I
Series of 2019.
ANNEX “1”