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Plaintiff's Reply to Loan Dispute

1. This document is a reply filed in a civil case in the Regional Trial Court of Zamboanga City, Philippines between plaintiff VJD Lending Investor Zamboanga Inc. and defendants Baby Girl C. Asucarera, Baby Boy D. De Salinas, and Jesus Quema Carbon De Paya. 2. The plaintiff denies the allegations in defendant Asucarera's answer, namely that the true loan amount was P50,000 rather than the P500,000 stated in the promissory note, and that the defendant made payments exceeding P20,000 to satisfy the loan. 3. The plaintiff also argues that the obligation cannot be considered prescribed or extinguished by compensation,

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204 views3 pages

Plaintiff's Reply to Loan Dispute

1. This document is a reply filed in a civil case in the Regional Trial Court of Zamboanga City, Philippines between plaintiff VJD Lending Investor Zamboanga Inc. and defendants Baby Girl C. Asucarera, Baby Boy D. De Salinas, and Jesus Quema Carbon De Paya. 2. The plaintiff denies the allegations in defendant Asucarera's answer, namely that the true loan amount was P50,000 rather than the P500,000 stated in the promissory note, and that the defendant made payments exceeding P20,000 to satisfy the loan. 3. The plaintiff also argues that the obligation cannot be considered prescribed or extinguished by compensation,

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Vj Delatado
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© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
  • Reply
  • Verification
  • Notarial Information

Republic of the Philippines

REGIONAL TRIAL COURT 9TH JUDICIAL REGION Branch ____ Zamboanga City
THE VJD LENDING INVESTOR ZAMBOANGA INC., herein Represented by its Manager May Ann J. Ekeena, Plaintiff, -versusCivil Case No. __________ For: SUM OF MONEY BABY GIRL C. ASUCARERA, BABY BOY D. DE SALINAS, and JESUS QUEMA CARBON DE PAYA, Defendants, x- - - - - - - - - - - - - -x

R E P L Y
COMES NOW, Plaintiff, unto this Honorable Court, most

respectfully manifest that on March 25, 2013, she received a copy of the Reply of Defendant BABY GIL C. ASUCARERA in the above-entitled case, and by way of a REPLY to new matters

alleged therein hereby state and thus: 1. That plaintiff denies and controverts the allegation in paragraph 4 of the ANSWER concerning the true amount of the loan, the best evidence concerning the same being the Promissory Note attached to the complaint; 2. That contrary to the allegations of the defendant, the actual amount of the loan was P500,000.00 and not

P50,000.00. The Promissory Note attached as Annex 1Asucarera et seq. is a clear alteration of the true amount of P500,000.00; 3. That it is not true that defendants made payments of any amount of the loan and much less that said payments

exceeded the actual amount P20,000.00;

2 4. That contrary to the allegations of the defendant, her obligation has not prescribed because repeated demands have been made upon her within the prescriptive period; 5. That neither is it true that the said obligation has been extinguished by compensation. The truth of the matter is that while plaintiff indeed bought a parcel of land from defendant, the purchase price thereof was completely and fully paid and satisfied as acknowledged by the

defendant-seller in the deed of absolute sale; Respectfully submitted. City of Zamboanga, Philippines, February 14, 2013. VEEJAY D. RAFAELA Counsel for the Defendant No. 025, Canelar Street, Zamboanga City PTR No. 0202234; Jan. 08, 2013/ZC IBP OR No. 111755849; Jan. 09, 2013/ZC MCLE Compliance Number 11120015418 Roll No 3832212. Republic of the Philippines) CITY OF ZAMBOANGA. . . . . ) S.S. x- - - - - - - - - - - - - x VERIFICATION I, MAY ANN J. EKEENA, of legal age, single, and with address at 143-C Divisoria, Zamboanga City, after having been sworn in accordance with law, hereby depose and say: That I am the representative of the plaintiff VJD Lending Investor Zamboanga Inc., in the above-entitled case as duly authorized by its Board of Trustees; that I have caused the foregoing REPLY to be prepared; that I have read and understood the contents of the same; ad that the allegations therein are true and correct based on my own knowledge and authentic documents; IN WITNESS WHEREOF, I have hereunto set my hand on this ___ day of March 2013 in the City of Zamboanga, Philippines. MAY ANN J. EKEENA Affiant
SUBSCRIBED AND SWORN to before me on this ___ day of March 2013 in the City of Zamboanga, Philippines.

VANESSA JOY RAFAELA DELATADO Notary Public Until December 31, 2014 Zamboanga City PTR No. 020931; Jan. 07, 2013/ZC BP OR No. 755849; Jan. 09, 2013/ZC
Doc. No. ___; Page No. ___; Book No. ___; Series of 2013

Republic of the Philippines REGIONAL TRIAL COURT 9TH JUDICIAL REGION Branch ____ Zamboanga City THE VJD LENDING INVEST
2 4. That contrary to the allegations of the defendant, her obligation has not prescribed because repeated demands have
3 VANESSA JOY RAFAELA DELATADO Notary Public

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