Republic of the Philippines

Metropolitan Trial Court

Branch __
Quezon City

Mr. Peter Banag, Plaintiff, Case No:_______

For: Civil and Moral Damages.

-versus-

Mr. Arthur Sison, Defendant,

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

ANSWER TO COMPLAINT

COMES NOW, the defendant, through the undersigned counsel and

unto this Honorable Court, most respectfully avers:

ADMISSION AND DENIAL

1. That he ADMITS the contents of paragraphs 1, 2, & 3 of the

Plaintiff.
2. That he ADMITS the contents of paragraphs 4, 5, & 6.
3. That he DENIES the contents of paragraph 7, he has lack of
knowledge of the circumstance and he is not present on the happening.
4. That he ADMITS the contents of paragraph 8.
5. That he ADMITS the contents of paragraph 9 on the context of
someone knocking on his gate.
6. That he DENIES the contents of paragraph 10 since the dog is
inside his premises as what they usually do and there was clear negligence
of the Plaintiff for letting his daughter go out knowing the possible danger
around for her age.
7. That he DENIES the contents of paragraphs 11 and 12, since he
was not in the presence of the happening.
8. That he ADMITS the contents of paragraphs 13, 14, 15, 16, and 17.
9. That he ADMITS the contents of paragraph 18.

PRAYER

WHEREFORE, the defendant respectfully prays that the complaint

be dismiss with costs against the plaintiff.

Other relief and remedies are as may be deemed just and equitable
under the premises likewise prayed.

City of Manila, September 27, 2012.

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 Reply of the Defendant
BY:

ATTY. CESAR CLINTON A. VILLAFLOR, JR.

Counsel for the Defendant
PTR No. 154069 2-20-2014 Manila City
IBP No. 912690 2-21-2014 Manila City
Roll No. 696969
MCLE Ex. No. 111-000769 1-13-2012
For 3rd compliance

EXPLANATION

Copy of the foregoing ANSWER was served to plaintiffs counsel

by registered mail due to time and distance constraints .

ATTY. CESAR CLINTON A. VILLAFLOR, JR.

VERIFICATION AND CERTIFICATION AGAINST FORUM

SHOPPING
I, Mr. ARTTHUR SISON, of legal age, married, Filipino Citizen, a Father
and a resident of 12 Annapolis Street, Cubao, Quezon City, after being
sworn according to law, hereby depose and state that;

1. I am a defendant in the above-stated case;

2. I caused the preparation of the foregoing reply to complaint;
3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and/or on the basis of copies
of documents and records in my possession;
4. I have not commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

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5. To the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding has
been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that fact
within five (5) days therefrom to this Honorable Court.

ARTHUR SISON
AFFIANT

In witness thereof, I, Mr. ARTHUR SISON , have hereunto set my

hand this 29th of January at Quezon City.

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