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    Regional Trial Court

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    Lien Patrick
    1) This document is an Answer filed by the defendant Trafalgar Law in response to a civil complaint brought by the plaintiff Monkey D Luffy for collection of a sum of money. 2) The defendant admits taking out a loan from the plaintiff but denies the interest rates and other charges cited in the complaint, stating these terms were not fully explained. 3) The defendant claims to have fully paid off the loan in May 2017 as evidenced by attached payment slips, and denies owing any remaining balance. The defendant requests the complaint be dismissed for lack of merit.

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    Regional Trial Court

    Uploaded by

    Lien Patrick
    40 views3 pages
    1) This document is an Answer filed by the defendant Trafalgar Law in response to a civil complaint brought by the plaintiff Monkey D Luffy for collection of a sum of money. 2) The defendant admits taking out a loan from the plaintiff but denies the interest rates and other charges cited in the complaint, stating these terms were not fully explained. 3) The defendant claims to have fully paid off the loan in May 2017 as evidenced by attached payment slips, and denies owing any remaining balance. The defendant requests the complaint be dismissed for lack of merit.

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    1) This document is an Answer filed by the defendant Trafalgar Law in response to a civil complaint brought by the plaintiff Monkey D Luffy for collection of a sum of money. 2) The defendant admits taking out a loan from the plaintiff but denies the interest rates and other charges cited in the complaint, stating these terms were not fully explained. 3) The defendant claims to have fully paid off the loan in May 2017 as evidenced by attached payment slips, and denies owing any remaining balance. The defendant requests the complaint be dismissed for lack of merit.

    Copyright:

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

    Regional Trial Court

    Uploaded by

    Lien Patrick
    1) This document is an Answer filed by the defendant Trafalgar Law in response to a civil complaint brought by the plaintiff Monkey D Luffy for collection of a sum of money. 2) The defendant admits taking out a loan from the plaintiff but denies the interest rates and other charges cited in the complaint, stating these terms were not fully explained. 3) The defendant claims to have fully paid off the loan in May 2017 as evidenced by attached payment slips, and denies owing any remaining balance. The defendant requests the complaint be dismissed for lack of merit.

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    © 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

    REGIONAL TRIAL COURT


    6th Judicial Region
    Branch 12
    Makati City

    Monkey D Luffy Plaintiff, CIVIL CASE No. 16-0956-2341

    - versus – FOR: COLLECTION OF SUM OF


    MONEY.

    Trafalgar Law Defendant.


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

    ANSWER

    Defendant, thru the undersigned counsel, most respectfully file their


    ANSWER in response, to the complaint of the Plaintiff and avert that:

    1. The defendant admits paragraph 1 and 2 of the complaint.


    2. The defendant admits that he took a loan from Plaintiff but specially
    deny paragraph 3 of the complaint. The true on the matter is, when
    they signed the pro forma promissory note from the plaintiff there
    was no detail with regards to the interest rates and other charges the
    plaintiff is responsible for.
    3. The defendant admits paragraph 4, 5, 6 of the complaint regarding
    the owner of the motor vehicle, but deny about the paragraph about
    the Deed of Assignment all terms and conditions were fully explain
    properly.

    4. The defendant especially deny paragraph 7 as defendant literally full


    filled his obligation by paying full the loan agreement in May 2017 .
    Photocopies of the Deposit/Loading slip are here to attach and mark
    as Annex “A”.
    5. Defendant deny paragraph 8 as the defendant have no sufficient
    knowledge about it.

    Affirmative defense

    1. Article 1231 of the Civil Code: Obligations are extinguished by


    payment or performances
    2. Article 1235. When the obligee accepts the performance, knowing its
    incompleteness or irregularity, and without expressing any protest or
    objection, the obligation is deemed fully complied with.

    WHEREFORE, PREMICES CONSIDERED, defendant respectfully pray


    that the instant complaint be immediately dismiss for lack of merit.

    BARAG LAW OFFICE


    Counsel for the Defendant
    7-C Crispa Ave., San Lorenzo Village,
    Pamplona III, 1712 Makati City
    E-mail: barag.law@gmail.com

    By:

    Marlon Sy
    Roll No. 52354
    PTR No. 101229105-J/01-04-2016
    IBP No. 1017535/01-04-2016
    MCLE Compliance No. V-0023447
    dated April 11, 2016

    Copy furnished:

    ATTY. Raposon
    Counsel for the Plaintiff
    XXXXX

    BT
    STF Law Firm, Suite 704, Hi-Residences Bldg.,
    23th ST. Bonifacio High Taguig City

    VERIFICATION
    I, Trafalgar Law, of legal age and Filipino, after having been duly
    sworn to in accordance with law, depose and state THAT:

    I am the defendants in the above entitled case; I have caused the


    preparation of the foregoing document and I have read the same and the
    contents of which are true and correct of my own knowledge and/or on the
    basis of authentic documents.

    AFFIANT SAYETH NAUGHT.

    In witness whereof, I hereunto affix my signature this May 10, 2018.

    TRAFALGAR LAW
    DEFENDANT

    REPUBLIC OF THE PHILIPPINES)


    MAKATI).

    SUBSCRIBED AND SWORN to before me this May 10, 2018;


    defendant exhibiting to me his TIN I.D. No. 108-555-758-00.

    WITNESS MY HAND AND SEAL this May 10, 2018.

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