Republic of the PhilippinesMunicipal Trial CourtFirst Judicial RegionBaguio CityBranch _____

Juan Go,Plaintiff,Civil Case No.________For: Collection of Sum of Money Versus -

Juana Sy,Defendant.x-------------------x

ANSWER

COMES NOW the defendant through the undersigned counsel, by way of answer to the plaintiffs consent, hereby respectfully alleges that:

1. She admits the allegations in paragraph 2 of the complaint regarding her personal circumstances;

2. She is without knowledge or information to form a belief as to the truth of the allegations in paragraphs 1, 4, 6, 8 and 9 of the complaint;

3. She denies the material allegations in paragraph3 in the complaint, since such allegations are meant to unjustly enrich the Plaintiff at the Defendants expense. The truth to the matter is that the principal obligation of the defendant only amounts to three hundred thousand Philippine pesos (P300,000.00) as where the defendant has agreed to. But due to an unconscionable and enslaving monthly interest of 12% defendant later on learned that she was deceived into signing the agreement and that she is forced to pay an obligation of an aggregate amount of indebtedness amounting to One Million one hundred sixty four thousand Philippine pesos (P1,164,000.00), exclusive of other charges;

4. She denies that there was a valid demand to pay stated in paragraph 7 of the complaint that the demand to pay her obligation was made on the 13th of February 2015, hence no formal demand has been made;

5. Plaintiffs complaint does not state a cause of action;

6. She admits that sometime on the 14th of February 2015, defendant incurred and indebtedness of Three Hundred Thousand Philippine Pesos (P300,000.00) with Plaintiff;

7. Due to the long relationship of Plaintiff and Defendant as neighbors, Defendant was deceived into signing a promissory note which she thought contained only a reasonable interest rate per Defendants and Plaintiffs prior oral agreement;

8. Upon further review of the Promissory Note which she received later, Defendant discovered with sheer surprise that the interest rate on the receipt is at Twelve percent (12%) monthly and not annually as to their oral agreement;

WHEREFORE, it is respectfully prayed that the Plaintiffs complaint be dismissed with costs against the Plaintiff. The Defendant further prays for such other relief as the Honorable Court may deem just and equitable.

Baguio City, June 15, 2015.

ATTY. CHENELYN N. BARBARCounsel for the Defendant#7 Harrison Road, Baguio CityRoll No. 570522 IBP No.600488 MCLE Compliance No. 14-00069924

VERIFICATION AND CERTIFICATION

I, Juana Sy, of legal age, Filipino, single and a resident of #2 Harrison Road, Baguio City, after having been duly sworn in accordance with law hereby state that:

1. I am the defendant in the above entitle case; that I have caused the preparation of the foregoing Answer Pleading; and that all the allegations stated herein are true and correct of my own knowledge and supported by authentic documents;

2. That I have not commenced any other action or proceeding involving the same parties or issues in any other honorable court or tribunal; that to the best of my knowledge no such action or proceeding involving the same matter is pending or has been terminated in any other honorable court or tribunal; and that I undertake to duly report that fact upon knowledge within five (5) days therefrom to this Honorable Court.

Juana Sy Affiant

SUBSCRIBED AND SWORN to before me this 15th of June 2015 at Baguio City after exhibiting to me her Drivers License with DL No. A01-456-131511 issued in Baguio City on December 12, 2014.

ATTY. CHENELYN N. BARBARNotary Public for and in the City of BaguioUntil December 31, 2015Doc No: ____#7 Harrison Road, Baguio CityPage No. :___Roll No. 570522 Book No.:___IBP No.600488 Series of 2015MCLE Compliance No. 14-00069924