Republic of The Philippines Municipal Trial Court in Cities: Plaintiff

REPUBLIC OF THE PHILIPPINES
FOURTH JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES
Calapan City
MAINE DEI ATAYDE, CIVIL CASE NO. CV-1019

Plaintiff,
- versus - - for -
ARJO SANCHEZ MENDOZA, UNLAWFUL DETAINER

Defendant.
X --------------------------------- X
ANSWER
COMES NOW, DEFENDANT ARJO SANCHEZ MENDOZA, through the
undersigned counsel and by way of Answer to the Complaint in the above -
entitled case, most respectfully state that:
1. The Defendant received the copy of the Summons on May 05, 2021;
2. Defendant admits paragraph 1 of the Complaint as far as to the
personal circumstances of the Plaintiff;
3. Defendant admits paragraph 2, as far as to the personal
circumstances of the Defendant;
4. Defendant admits paragraphs 3 and 4;
5. Defendant denies the allegations made in paragraph 5 for they are
untrue and baseless. Defendant was able to pay rental fees from
January 7 2018 to October 19, 2019, as shown in the receipts
marked as Exhibits A, B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q,
R, S, T, and U, respectively;
6. Defendant denies paragraph 6 for being untrue, having never received
such demand letters;
7. Defendant admits paragraph 7; shocked to receive the cancellations
when she was paying regularly;
8. Defendant partially admits the allegations in paragraph 8, as to
receiving the notice. However, she denies the existence of overdue
accounts due to her regular payments;
9. Defendant partially admits paragraph 9, as to the posting of the
notice at the townhouse. However, she denies having received the
actual forfeiture letter;
10. Defendant denies paragraph 10, as she has never skipped a
payment of her rental fees.
11. Defendant denies paragraph 11, as she has always been timely
with delivering the rent.
12. Defendant denies paragraph 12, as her continued occupation of
the property is justified under the Contract to Sell executed between
her and the plaintiff.
DEFENSES
On the basis of the foregoing allegations, and in further support of the
specific denials herein set forth, Defendant respectfully alleges that:
1. The Defendant has already paid the rental fees, as shown in the
receipts
2. The issue of not having received the same lies not with the Defendant,
but with the Plaintiff's helper, Mr. Vincenzo Cassano, who received all
the payments starting from January 07, 2018 to October 19, 2019.
3. That due to the filing of the Complaint against her, herein defendant
was constrained to engage the services of the undersigned counsel at
an agreed attorney's fee of Thirty Thousand Pesos (Php 30,000.00)
and an appearance fee of Two Thousand Peses (Php 2,000.00) per
court appearance.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this
Honorable Court that the foregoing Answer be ADMITTED AND CONSIDERED
and:
1. On the basis of the foregoing specific denials and defenses, answering
defendant most respectfully prays that the above - entitled case be
dismissed;
2. That the Contract to Sell be enforced and the Notice to Vacate be void
for being baseless and untrue;
3. That the plaintiff be held liable to pay moral damages and attorney's
fees; and
4. That the plaintiff be made to pay the costs of the suit.
Other reliefs just and equitable under the premises are likewise prayed
for.
Calapan City, May 10, 2021.
ALEXIS S. ESPARAGOZA
Counsel for Defendant
Copy Furnished:
Atty. Zyreen Kate B. Cataquis

Counsel for the Plaintiff
VERIFICATION AND CERTIFICATION
OF NON-FORUM SHOPPING
Republic of the Philippines )S.S.

City of Calapan )
I, ARJO SANCHEZ MENDOZA, of legal age, Filipino citizens and with

postal address at Pinagkaisahan St., Camilmil, Calapan City, after having been
sworn to in accordance with law hereby depose and say:
1. That I am the defendant in the above-entitled case;
2. That I have caused the preparation of the foregoing ANSWER and

that the contents thereof are true and correct of my own personal
knowledge and based authentic documents;
3. That I have not commenced any other action or proceeding

involving the same issues in this Honorable Court, in the Supreme Court
or in any other tribunal or agency, that to the best of my knowledge, no
such action or proceeding is pending in this Honorable Court, in the
Supreme Court or in any other tribunal or agency, and should I learn
that a similar action or proceeding has been filed or is pending in this
Honorable Court, in the Supreme Court or in any other tribunal or
agency, I undertake to report that fact within five (5) days therefrom to
this Honorable Court.
In witness whereof, I have hereunto set my hand this 10th day of May
2021.
ARJO SANCHEZ MENDOZA

Affiant
EXHBIT A
EXHIBIT B
EXHIBIT C
EXHIBIT D
EXHIBIT E
EXHIBIT F
EXHIBIT G
EXHIBIT H
EXHIBIT I
EXHIBIT J
EXHIBIT K
EXHIBIT L
EXHIBIT M
EXHIBIT N
EXHIBIT O
EXHIBIT P
EXHIBIT Q
EXHIBIT R
EXHIBIT S
EXHIBIT T
EXHIBIT U

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REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

MAINE DEI ATAYDE, CIVIL CASE NO. CV-1019

ARJO SANCHEZ MENDOZA, UNLAWFUL DETAINER

Atty. Zyreen Kate B. Cataquis

Republic of the Philippines )S.S.

I, ARJO SANCHEZ MENDOZA, of legal age, Filipino citizens and with

1. That I am the defendant in the above-entitled case;

2. That I have caused the preparation of the foregoing ANSWER and

3. That I have not commenced any other action or proceeding

ARJO SANCHEZ MENDOZA

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