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    Answer For Complaint For Forcible Entry

    Uploaded by

    Giulia Madera
    1. Dionisio Uyay is being sued by Anacleto Mangaser for forcible entry onto a property in Caba, La Union. However, Uyay denies the allegations and claims he has lived on and improved the land his entire life. 2. Uyay admits living in the area his whole life and starting to occupy the land as a child. He made further improvements like cultivating the land and building structures. 3. Uyay denies intruding onto Mangaser's property and claims the boundaries were never clearly defined. He is asking that the case against him be dismissed and is seeking damages for harassment and legal fees.

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    © All Rights Reserved
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    Answer For Complaint For Forcible Entry

    Uploaded by

    Giulia Madera
    265 views3 pages
    1. Dionisio Uyay is being sued by Anacleto Mangaser for forcible entry onto a property in Caba, La Union. However, Uyay denies the allegations and claims he has lived on and improved the land his entire life. 2. Uyay admits living in the area his whole life and starting to occupy the land as a child. He made further improvements like cultivating the land and building structures. 3. Uyay denies intruding onto Mangaser's property and claims the boundaries were never clearly defined. He is asking that the case against him be dismissed and is seeking damages for harassment and legal fees.

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    Answer for Complaint for Forcible Entry

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    1. Dionisio Uyay is being sued by Anacleto Mangaser for forcible entry onto a property in Caba, La Union. However, Uyay denies the allegations and claims he has lived on and improved the land his entire life. 2. Uyay admits living in the area his whole life and starting to occupy the land as a child. He made further improvements like cultivating the land and building structures. 3. Uyay denies intruding onto Mangaser's property and claims the boundaries were never clearly defined. He is asking that the case against him be dismissed and is seeking damages for harassment and legal fees.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    265 views3 pages

    Answer For Complaint For Forcible Entry

    Uploaded by

    Giulia Madera
    1. Dionisio Uyay is being sued by Anacleto Mangaser for forcible entry onto a property in Caba, La Union. However, Uyay denies the allegations and claims he has lived on and improved the land his entire life. 2. Uyay admits living in the area his whole life and starting to occupy the land as a child. He made further improvements like cultivating the land and building structures. 3. Uyay denies intruding onto Mangaser's property and claims the boundaries were never clearly defined. He is asking that the case against him be dismissed and is seeking damages for harassment and legal fees.

    Copyright:

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

    Republic of the Philippines

    Municipal Trial Court


    Caba, La Union

    ANACLETO C. MANGASER, CIVIL CASE NO. ___________


    represented by his Attorney-in-fact
    EUSTAQUIO DUGENIA, 
    For:
    Plaintiff,

    Forcible Entry With Damages


    - versus - 
     

    DIONISIO UGAY,
     Defendant,

    X------------------------------------------------/

     ANSWER

    DEFENDANT, through the undersigned counsel, and


    unto the Honorable Court most respectfully file his Answer in
    response to the Complaint of the Plaintiff and interpose as well his
    defenses and counterclaim against the plaintiff, viz:

    1. Defendant strongly denies the material allegations of the


    complaint;

    2. Defendant admitted that he had been a resident of Samara,


    Aringay, La Union, since birth and when he reached the age of
    reason, he started occupying a parcel of land in that place then
    know as Sta. Lucia, Aringay, La Union; that years later, this parcel
    of land was designated as part of Santiago Sur, Caba, La Union due
    to a survey made by the government;

    3. Defendant denies the allegations contained in paragraph 3. The


    Defendant did not construct a residential house; however, he
    introduced more improvements on the property by cultivating the
    land, and in March 2006, he put up a “bahay kubo”; that in
    October 2006, he installed a fence made of “bolo” to secure the
    property; that in installing the fence, he was guided by the concrete
    monuments which he knew to be indicators of the boundaries of
    Plaintiff’s property;

    4. Insofar as paragraph 7 of the Complaint, it was not correct to say


    that the Defendant refused to vacate and surrender the premises
    despite receipt of the demand letters because in his letter-reply, he
    assured the Plaintiff that he would voluntarily vacate the premises
    if he would only be shown to have intruded into Plaintiff’s titled lot
    after the boundaries were pointed out to him;

    5. Plaintiff was never in actual possession of the property occupied


    by him, and it was only on October 31, 2006 when he discovered
    the al legccl intrusion;

    6. Defendant had experienced harassment causing sleepless nights,


    anxiety and besmirched reputation considering that he is a
    teacher. In this regard, the Plaintiff should be made liable to pay
    moral damages amounting thirty thousand pesos (P30,000.00);

    7. In instituting this unwarranted and clearly unfounded suit


    against the Defendant, Plaintiff had acted in a wanton, fraudulent,
    reckless and malevolent manner, by way of example or correction
    for the public good, Plaintiff should be made liable to pay
    Defendant exemplary damages in the total amount of fifty thousand
    pesos (P50,000.00);

    8. As a further consequence of the malicious and wrongful filing of


    the present action, Defendant was constrained to hire the services
    of counsel for a legal fee of fifty thousand pesos (P50,000.00), plus
    three thousand pesos (P3,000.00) per court appearance, and to
    incur expenses of litigation for which plaintiff should be made to
    pay.
    PRAYER

    WHEREFORE, the defendant most respectfully prayed that


    this Honorable Court find generally in Defendant’s favor and
    against the Plaintiff, that the Plaintiff take nothing by way of
    Plaintiff’s Complaint for Forcible Entry With Damages, and for such
    other further relief as the court deems just and proper.

    This January 16, 2021, at Caba, La Union.

    ATTY. GIULIA ROSA C. MADERA


    Counsel for the Defense
    3 F Blommingdale Tower
    rd

    Caba, La Union, 2502


    Tel No. 0917-9345519
    Email: [email protected]
      

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