Metropolitan Trial Court Branch 198 Las Pinas City

REPUBLIC OF THE PHILIPPPINES
METROPOLITAN TRIAL COURT

BRANCH 198
LAS PINAS CITY
MR. ANDREW F. MEDINA

Plaintiff,
-versus-
Civil Case No. 4
For: “Ejectment”
MS. EVA CARINO BRUTAL,
Defendant.
x------------------------------------------x
ANSWER
COMES NOW DEFENDANT MS. EVA CARINO BRUTAL,

assisted by the Public Attorneys’ Office unto this Honorable Court, by way
of Answer to the Plaintiff’s Complaint, most respectfully avers that:
1. For lack of knowledge and information sufficient to form a belief as to

the truth and veracity of the complainant’s residence, Paragraph 1 of
the Complaint is specifically denied;
2. Defendant admits Paragraph 2 of the complaint being the personal

circumstances of the Defendant, as she is the lessee at #69 Hobart
St., ABC Homes, Las Piñas City;
3. Defendant denies Paragraph 3 of the Complaint that

the Plaintiff is the absolute owner and lessor of a property at #69
Hobart St., ABC Homes, Las Piñas City.
4. Defendant admits Paragraph 4 as only to the duration of period from 1

December 2017 to 30 November 2018.
The Defendant specifically denies that the Contract of Lease was
entered into agreement between the Defendant and Mr. Dela Cruz.
5. Defendant denies Paragraph 5 and 6 of the Complaint for lack of

knowledge and information sufficient to form a belief as to the truth
and veracity thereof.
Page 1 of 4 pages
6. Defendant admits Paragraph 7 of the Complaint, but denies that the
Defendant deprives the Plaintiff on
the house.
7. Defendant denies Paragraph 8, since the demand was only signed by Ms.
Ma. Nita Sabel—the agent of Mr. Juan Dela Cruz, property owner
of residential house and lot at#69 Hobart St., ABC Homes, Las Pinas
City.
8. Defendant admits Paragraph 9, but denies that Ms. Brutal refused to pay
her rental dues.
9. Defendant denies Paragraph 10 that she unlawfully possessed the subject

property.
10.Defendant denies Paragraph 11 for lack of truth and veracity of the

Certificate to File Action.
The Defendant respectfully states the following by way of SPECIAL

and AFFIRMATIVE DEFENSES:
11.That all the foregoing allegations are repleaded insofar as they may be
material, germane and relevant to the herein affirmative defenses;
12.That herein Defendant started to occupy the subject property in 2009, by

virtue of an agreement between the Defendant and Juan Dela Cruz—
owner of the subject property;
13.The Defendant only received one letter from Ms. Ma. Nita Sabel dated
16 January 2019 demanding to vacate
the subject property to protect the interest of the Plaintiff, which they
alleged that the Plaintiff is the rightful owner of the subject property.
The 16 January 2019 letter is the only letter received by the
Defendant, contrary to what is indicated in the letter that they have
sent several demand letters to the Defendant.
14.The Plaintiff showed no legal documents indicating

the transfer of real estate property rights from Bobby Dela Cruz. The
Defendant was amazed and a quandary how the Plaintiff became the
owner of subject property and the legality of transfer of ownership.
Page 2 of 4 pages
PRAYER
WHEREFORE, it is most respectfully prayed of this Honorable Court

that after due notice and hearing, judgment be rendered DISMISSING the
instant case for utter lack of merit.
Defendant prays for further relief which may be deemed just and
equitable under the premises.
Quezon City, 9 February 2019.
MS. EVA CARINO BRUTAL
Assisted by:
PUBLIC ATTORNEY’S OFFICE
Counsel for the Defendant
By:
ATTY. JAMES MATTHEW A CASTILLO

Public Attorney II
Roll no. 12345
IBP NO. 123456 01-08-09
Compliance No. II- 123155 07/24/0
VERIFICATION
I, EVA CARINO BRUTAL, of legal age, Filipino, after having been

duly sworn to in accordance with law, depose and say:
1. That I am the DEFENDANT in the instant case;

2. That I have caused the preparation of the foregoing ANSWER TO
THE COMPLAINT;
3. That I have read all the allegations therein and that the same are
true of my own personal knowledge based on existing authentic
documents.
EVA CARINO BRUTAL

Affiant
Page 3 of 4 pages
REPUBLIC OF THE PHILIPPINES )
QUEZON CITY ) S.S.
SUBSCRIBED AND SWORN TO before me this ___________ day

of March 2009, affiant exhibited to me her Senior Citizen I.D. No.1438700
issued on Jan. 25, 1995, at Quezon City, Philippines.
Doc. No._______ ATTY. MARIANNE A. TARO

Page No._______ PUBLIC ATTORNEY II
Book No._______ PURSUANT TO R.A. 9406
Series No. 2009
Copy furnished:
Atty. Ma. Khristina Cayabyab

41-D C.M Recto st. Pamplona, Las Piñas City
EXPLANATION
Due to lack of manpower in the office, counsel for the Complainant

was furnished a copy of this Answer by registered mail in lieu of personal
service.
ATTY. JAMES MATTHEW A CASTILLO
Page 4 of 4 pages

Metropolitan Trial Court Branch 198 Las Pinas City

Uploaded by

Copyright:

Available Formats

Metropolitan Trial Court Branch 198 Las Pinas City

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Metropolitan Trial Court Branch 198 Las Pinas City

Uploaded by

Copyright:

Available Formats

REPUBLIC OF THE PHILIPPPINES

METROPOLITAN TRIAL COURT

MR. ANDREW F. MEDINA

COMES NOW DEFENDANT MS. EVA CARINO BRUTAL,

1. For lack of knowledge and information sufficient to form a belief as to

2. Defendant admits Paragraph 2 of the complaint being the personal

3. Defendant denies Paragraph 3 of the Complaint that

4. Defendant admits Paragraph 4 as only to the duration of period from 1

5. Defendant denies Paragraph 5 and 6 of the Complaint for lack of

9. Defendant denies Paragraph 10 that she unlawfully possessed the subject

10.Defendant denies Paragraph 11 for lack of truth and veracity of the

The Defendant respectfully states the following by way of SPECIAL

12.That herein Defendant started to occupy the subject property in 2009, by

14.The Plaintiff showed no legal documents indicating

WHEREFORE, it is most respectfully prayed of this Honorable Court

Quezon City, 9 February 2019.

MS. EVA CARINO BRUTAL

ATTY. JAMES MATTHEW A CASTILLO

I, EVA CARINO BRUTAL, of legal age, Filipino, after having been

1. That I am the DEFENDANT in the instant case;

EVA CARINO BRUTAL

SUBSCRIBED AND SWORN TO before me this ___________ day

Doc. No._______ ATTY. MARIANNE A. TARO

Atty. Ma. Khristina Cayabyab

Due to lack of manpower in the office, counsel for the Complainant

ATTY. JAMES MATTHEW A CASTILLO

You might also like