ANSWER

Republic of the Philippines
MUNICIPAL CIRCUIT TRIAL COURT

Eight Judicial Region
Branch 8
Salcedo, Eastern Samar
ELY MERRO
Plaintiff
CIVIL CASE NO. __________
-versus- For: Collection of Sum of Money
with Damages
ZEKE SOLAMO
Defendant
X - - - - - - - - - - - - - - - - -- - - - - - - - -X
ANSWER
The Defendant, by the undersigned counsel, to this Honorable Court and in

answer to the Plaintiff’s complaint, most respectfully aver:
1. That the Defendant admit the allegation contained in paragraph 2 and 4 of

the complaint but deny the allegation contained in paragraph 5 of same
having no knowledge sufficient to form a belief as to the truth and veracity
of the same, the true fact being embodied in the special affirmative
defense answer; and
2. That likewise deny the allegation contained in paragraph 6 of the
complaint being baseless under circumstances.
SPECIAL AFFIRMATIVE DEFENSES
1. That the complaint has no cause of action;
2. That defendant has indeed signed a document called a promissory note but
hesitant to what is stipulated of 1% per annum in an installment basis
including the agreed principal and its remaining principal obligation but then
plaintiff assured the defendant to ignore the said stipulation, as the prime
purpose of the Promissory note is only that the defendant was indebted to the
plaintiff in the sum of PHP 75, 000.00 pesos only which was due and
demandable on January 20, 2024;
3. That defendant has paid the principal obligation amounting to PHP 21, 000.00
pesos and the annual interest of three years amounting to PHP 22, 500.00
pesos on the January 19, 2024 at 10:00 AM inside the Brgy Hall of Buabua
Salcedo Eastern Samar for the purpose that such payment was made, a copy
herein is the minutes of the Barangay Secretary of Brgy Buabua duly signed
by her and the Brgy. Captain, the four Lupong Tagapamayapa and three
barangay tanods of the said barangay present therein, hereto attached as
Exhibit “1” and a CCTV footage to which recorded that defendant and the
plaintiff together with four Lupong Tagapamayapa, three barangay tanods, the
barangay captain and the barangay chairman has entered the barangay hall
to settled the issue and handed over personally the remaining obligation with
a total amount of PHP 43, 500.00 pesos in cash hereto attach as Exhibit “2”;
4. That by reason of the filing of this instant action, the defendants had suffered
mental anguish, wounded feelings, sleepless nights, serious anxities and
other similar sufferings for which the same could be atoned by condemning
the plaintiff to pay them the sum of Twenty Thousand Pesos ( P20,000.00 ) as
moral damages and to give a lesson to the plaintiff and to deter others from
doing the same act, a further sum of Ten Thousand Pesos ( P 10,000.00 ) as
sundry litigation expenses;
WHEREFORE, premises considered, it is most respectfully prayed that

judgment issue in favor of the defendants and against the plaintiff, the
following:
a. Ordering the dismissal of the complaint with costs against the plaintiff;
b. Ordering the plaintiff to pay the defendants the following sums: Twenty
Thousand Pesos (P20,000.00) as moral damages; Ten Thousand
Pesos (P10,000.00) as exemplary damages; Fifteen Thousand Pesos
(P15,000.00) as acceptance for attorney’s fee plus Five Thousand
Pesos (P5,000.00) per appearance in court of counsel and Ten
Thousand Pesos (P10,000.00) as sundry litigation expenses; and
c. Such other reliefs and remedies just and equitable in the premises.
Salcedo, Eastern Samar, February 5, 2024.
LANIE C. LAURIO
Counsel for the Defendants
Roll of Attorney No. 56567
Copy furnish IBP O.R. No. 654321 (11/20/24)
PTR O.R. No. 0134876(10/10/23)
Salcedo Eastern Samar
MCLE No. 145879 (01/08/23)
CERTIFICATION
I, ZEKE SOLAMO, Filipino, of legal age, resident of Brgy Palanas, Salcedo

Eastern Samar, Philippines, under oath, hereby depose and say: I am the defendant in
the above-entitled case; that I have caused the preparation and filing of the foregoing
answer; that I have read and understood all the allegations contained therein and that
the same are true and correct to the best of my knowledge and belief.
Salcedo Eastern Samar, February 5, 2024.
ZEKE SOLAMO
Defendant
SUBSCRIBED AND SWORN to before me this 25th of February 2015 at Salcedo

Eastern Samar, Philippines.
LANIE C. LAURIO
Counsel for the Defendants
Roll of Attorney No. 56567
Copy furnish IBP O.R. No. 654321 (11/20/24)
Plaintiff Lawyer PTR O.R. No. 0134876(10/10/23)
Salcedo Eastern Samar
MCLE No. 145879 (01/08/23)

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Republic of the Philippines

MUNICIPAL CIRCUIT TRIAL COURT

The Defendant, by the undersigned counsel, to this Honorable Court and in

1. That the Defendant admit the allegation contained in paragraph 2 and 4 of

SPECIAL AFFIRMATIVE DEFENSES

1. That the complaint has no cause of action;

WHEREFORE, premises considered, it is most respectfully prayed that

Salcedo, Eastern Samar, February 5, 2024.

I, ZEKE SOLAMO, Filipino, of legal age, resident of Brgy Palanas, Salcedo

Salcedo Eastern Samar, February 5, 2024.

SUBSCRIBED AND SWORN to before me this 25th of February 2015 at Salcedo

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