Answer: Republic of The Philippines Regional Trial Court Third Judicial Region Branch - Angeles City

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Republic of the Philippines

REGIONAL TRIAL COURT


THIRD JUDICIAL REGION
Branch ____
Angeles City

Xxxx
Petitioner,

Case No. _________________


-versus-

Xxxx,
Respondents.

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

ANSWER
COMES NOW the defendant, by undersigned counsel, and in
answer to plaintiff's complaint, respectfully alleges:

1. That defendant admits paragraphs _____, _____ and ____


of the complaint;

2. That defendant is without knowledge or information to form a


belief as to the truth of the averments made in paragraphs _____,
_____ and ____ thereof;

3. That defendant DENIES specifically each and every material


allegations made in paragraphs _____, _____ and ____ of the
complaint, and alleges that (here state the substance of the matters
which defendant will rely upon to support such specific denial);

4. And as AFFIRMATIVE DEFENSES, the defendant alleges:

A. That (here state as many affirmative defenses as


defendant may have. All such grounds as would raise
issues of facts not arising upon specific denials must be
specifically pleaded. which may have basis in the
provisions of STATUTE OF LIMITATIONS, STATUTE OF
FRAUDS, ESTOPPEL, RELEASE OR DISCHARGE,
ETC.)

B. That (state other defenses):

5. As COUNTERCLAIM against the plaintiff, the defendant


alleges:

A. That defendant reproduces paragraphs _____, _____


and ____ of the plaintiff's complaint;

B. That (state defendant's claim for money or other relief


which he may have against the plaintiff; such
counterclaims need not diminish or defeat the recovery
sought by the plaintiff, but may claim relief exceeding in
amount or different in kind from that sought by the
plaintiff, provided that the court has jurisdiction to
entertain the claim);

WHEREFORE, it is respectfully prayed that:

(a) Prayer (for judgment in favor of defendant with respect


to plaintiff's complaint);

(b) Prayer (for judgment in favor of defendant with respect


to counterclaim); and

(c) For such other relief consistent with law and equity,
and for costs.

Agoo, La Union, _______________, 20__

_____________

- - - - - - - - - -- - - - - -- - - - -- - - --
RULE 6: KINDS OF PLEADINGS

SEC. 4. Answer.- An answer is a pleading in which a defending party


sets fourth his defenses. (4a)

SEC. 5. Defenses.- Defenses may either be negative or affirmative.


(a) A negative defense is the specific denial of the material fact
or facts alleged in the pleading of the claimant essential to his cause
or causes of action.

(b) An affirmative defense is an allegation of a new matter


which, while hypothetically admitting the material allegations in the
pleading of the claimant would nevertheless prevent or bar recovery
by him. The affirmative defenses include fraud, statute of limitations,
release payment, illegality, statute of frauds, estoppel, former
recovery, discharge in bankruptcy, and any other matter by way of
confession and avoidance. (5a)

SEC. 6. Counterclaim.—A counterclaim is any claim which a


defending party may have against an opposing party. (6a)

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