Answer with Compulsory- specific performance.docx

Republic of the PhilippinesREGIONAL TRIAL COURT9th Judicial RegionBranch 16Zamboanga City

SAM SUNG, CIVIL CASE NO. __03__ Plaintiff, FOR:SPECIFIC PERFORMANCEWITH DAMAGES -versus- GAL AXY, Defendant.X----------------------------------X

ANSWER TO COMPULSORY COUNTERCLAIM COMES NOW, the Plaintiff Sam Sung, through the undersigned counsel, unto this Honorable Court, in the above-entitled case, most respectfully allege:

1. Averments of the Defendant in Paragraphs 13 and 14 of the Answer are specifically denied for being mere conclusions of facts, disputable in proper proceedings;

2. Averment of the Defendant in Paragraph 15 is specifically denied since entitlement to such award for the alleged damage is still subject to the final determination of this case.

PRAYER WHEREFORE, premises considered, Answering Plaintiff pray unto this Honorable Court to render judgment, as follows:

1. To proceed in hearing the case until its final determination;

2. To grant the reliefs originally prayed for in the initial Complaint. Other reliefs as may be just and equitable in the premises are likewise prayed for.

Zamboanga City, Philippines

Atty. Fez BuokCounsel for PlaintiffPTR OR No. XXXXXXXXXXXXXIBP OR No. XXXXXXXXXXXXXRoll No. XXXXX --- oOo ---VERIFICATION/CERTIFICATION I, Sam Sung, of legal age, Single, Filipino, with postal address at Zamboanga City, Philippines, after having been duly sworn to an oath in accordance with law, do hereby depose and say:1. That I am the plainitff in the above-entitled case;2. That I have caused the preparation and filing of the foregoing Answer with Compulsory Counterclaim;3. That I have read the pleading and that the allegations therein are true and correct of our own personal knowledge or based on authentic records;4. That we further certify that there is no other case involving the same issues and parties before the Supreme Court, the Court of Appeals or Administrative bodies and other agencies of the government, exercising quasi-judicial functions, I shall inform the Honorable Commission about the same, within (5) days from knowledge thereof. IN WITNESS WHEREOF, we have hereunto set our hands this ___th day of ______ 20015, at Zamboanga City, Philippines. _____________Sam Sung

- Oath - Republic of the Philippines)City of Zamboanga. . . . . )S.S.X - - - - - - - - - - - - X) SUBSCRIBED AND SWORN TO before me this __th day of _____ 2015, Affiant exhibited to me his PhilHealth Card No. 14-025185567-2 issed on PhilHealth Main Office at Zamboanga City, Philippines. Doc. No.: 09 Atty. Fez BuokPage No.: 13 Notary PublicBook No.:40 Commission until December __, 2016Series of 2014

Copy furnished:

SPECIFIC PERFORMANCE 1 of 2 CIVIL CASE NO. 03