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    Answer Complaint-for-Damages rrp10182020

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    Madam Judger
    1. Airphil Express is being sued by several plaintiffs for damages related to plane tickets. 2. In its answer, Airphil Express admits some facts from the complaint but denies that it received any written demands from the plaintiffs. 3. Airphil Express also files a counterclaim seeking damages from the plaintiffs for initiating what it calls an "unwarranted and malicious" lawsuit.

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    Answer Complaint-for-Damages rrp10182020

    Uploaded by

    Madam Judger
    70 views3 pages
    1. Airphil Express is being sued by several plaintiffs for damages related to plane tickets. 2. In its answer, Airphil Express admits some facts from the complaint but denies that it received any written demands from the plaintiffs. 3. Airphil Express also files a counterclaim seeking damages from the plaintiffs for initiating what it calls an "unwarranted and malicious" lawsuit.

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    Answer_Complaint-for-Damages_rrp10182020

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    1. Airphil Express is being sued by several plaintiffs for damages related to plane tickets. 2. In its answer, Airphil Express admits some facts from the complaint but denies that it received any written demands from the plaintiffs. 3. Airphil Express also files a counterclaim seeking damages from the plaintiffs for initiating what it calls an "unwarranted and malicious" lawsuit.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    70 views3 pages

    Answer Complaint-for-Damages rrp10182020

    Uploaded by

    Madam Judger
    1. Airphil Express is being sued by several plaintiffs for damages related to plane tickets. 2. In its answer, Airphil Express admits some facts from the complaint but denies that it received any written demands from the plaintiffs. 3. Airphil Express also files a counterclaim seeking damages from the plaintiffs for initiating what it calls an "unwarranted and malicious" lawsuit.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 3

    1

    REPUBLIC OF THE PHILIPPINES


    REGIONAL TRIAL COURT
    NATIONAL CAPITAL REGION
    Branch 1
    Pasay City

    JUN CADUGO A. GUY,


    JIHAN B. TIN, Civil Case No. 10000000

    VILMA C. ANTON, For: Damages


    VICKI D. ARNA,

    Plaintiffs,

    -versus-

    AIRPHIL EXPRESS

    Defendant.

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

    ANSWER

    COMES NOW the Defendant, by the undersigned counsel, and in answer to


    Plaintiff's complaint, respectfully alleges:

    ADMISSIONS AND DENIALS

    1. That Defendant admits paragraphs 1, 2 and 3 of the Complaint with the


    additional averment that she may be served with all court processes
    through the undersigned counsel;

    2. That Defendant specifically denies the allegations in Paragraph 4 of the


    Complaint because the defendant did not receive any written demands
    mentioned therein.

    3. That Defendant knew that the Plaintiff did not have confirmed reservations
    for first class on any specific flight, although he had tourist class
    protection; that, accordingly, the issuance of a ticket was no guarantee
    that he would have a first class ride, but that such would depend upon the
    availability of first class seats. 

    1
    2

    By way of counterclaim, defendant alleges that:

    1. That by virtue of this unwarranted and malicious act initiated by the


    plaintiff, defendant was forced to engage counsel in the sum of
    P40,000.00.

    WHEREFORE, it is respectfully prayed that the complaint be dismissed and


    defendant be awarded the amount of P100,000.00

    Other equitable reliefs are likewise prayed for.

    City of Manila, Philippines. March 3, 2015

    ATTY. JUANICO FRANCISCO


    Counsel for Plaintiffs
    Unit 02, NBO Building,
    Crispina Ave., Las Pinas
    PTR. No. 987654-3120
    Roll No. 10000-0000000
    MCLE No. 567890-1234

    2
    3

    VERIFICATION

    The defendant, AIRPHIL EXPRESS, airlines who issued plane ticket at


    Pasay City, Philippines under oath declare that:

    1. We are the plaintiffs in the above-entitled case;


    2. We have caused the preparation of this complaint;
    3. We have read it and its contents are true and correct of my personal
    knowledge and/or based on authentic records.
    4. That I hereby certify under oath in this petition as follows:
    a. have not theretofore commenced any action or filed any action or
    claim involving the same issue in any court, tribunal or quasi-judicial
    agency and, to the best of my knowledge, no such other pending
    action or claim is pending therein;
    b. If there is such other pending action or claim, a complete statement of
    the present status thereof.

    IN WITNESS WHEREOF, WE hereunto affix signature this 9 March 2013.


     

    AIRPHIL EXPRESS
    Defendant

    SUBSCRIBED AND SWORN TO before me, a notary in and for the city named
    above, personally appeared the above person/s with their respective
    CTC/Passport, who is personally known to me to be the same and/ or identified
    through competent evidence of identity as defined by Rules on Notarial Practice,
    who presented the foregoing instrument and signed the instrument in my
    presence, and who took an oath before me as to such instrument.

    WITNESS MY HAND AND SEAL on March 9, 2015 at City of Manila, Philippines.

    ATTY. JUANICO FRANCISCO


    Counsel for Defendant
    Unit 02, NBO Building,
    Crispina Ave., Las Pinas
    PTR. No. 987654-3120
    Roll No. 10000-0000000
    MCLE No. 567890-1234
    Copy furnished:
    Name and Address of Counsel of the Other Parties

    Doc. No.: __________


    Page No.: _________
    Book No.:__________
    Series of __________

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