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REPUBLIC OF THE PHILIPPINES
                                      MUNICIPAL TRIAL COURT
                                           City of Baguio
                                             Branch 1


JOHN PAUL,
                 Plaintiff,
                 -versus-                                       CIVIL CASE NO. 222
JOY LOY,                                                        FOR: Unlawful Detainer
                 Defendant
x---------------------------------x


                                        REPLY- COMPLAINT


COMES NOW, the defendant through the undersigned counsel and unto this Honorable
Court, respectfully avers:



       1. That the defendant, JOY LOY, is of legal age, single, with residence and
postal address at Bontoc, Mountain province;



        2. That he is the defendant of the civil case number 222;



       3. That he rent an apartment, to the plaintiff (JOHN PAUL), by virtue of Contact
of lease;



      4. That he specifically denies the allegation of the plaintiff contained in the
complaint more particularly paragraph 5, 6 and 7 for being not true:



              a) That before 15 March 2012, the defendant already leaved the said
        premises, because they transferred to an apartment which is near on to his job;



                        b) That on 1 July 2012, the defendant did not accept any letter of
                 demand to vacate the said premises, for the reason that he already leaved
                 the said premises befor 15 March 2012;



                        c) That an oral demand by the plaintiff has never been happened,
                 for the reason that they did not see each other since he leaved the said
                 premises.
5) That he is executing this Reply – Complaint to attest to the truth of the
foregoing statements, and to move for the dismissal of the above case for lack of legal
and factual basis.



SUBSCRIBED AND SWORN TO before me this 27th day of August 2012, in the City of
Baguio, Philippines




                                                               ATTY. BJ MAYER

                                                            (Attorney for Defendant)

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Reply on complaint

  • 1. REPUBLIC OF THE PHILIPPINES MUNICIPAL TRIAL COURT City of Baguio Branch 1 JOHN PAUL, Plaintiff, -versus- CIVIL CASE NO. 222 JOY LOY, FOR: Unlawful Detainer Defendant x---------------------------------x REPLY- COMPLAINT COMES NOW, the defendant through the undersigned counsel and unto this Honorable Court, respectfully avers: 1. That the defendant, JOY LOY, is of legal age, single, with residence and postal address at Bontoc, Mountain province; 2. That he is the defendant of the civil case number 222; 3. That he rent an apartment, to the plaintiff (JOHN PAUL), by virtue of Contact of lease; 4. That he specifically denies the allegation of the plaintiff contained in the complaint more particularly paragraph 5, 6 and 7 for being not true: a) That before 15 March 2012, the defendant already leaved the said premises, because they transferred to an apartment which is near on to his job; b) That on 1 July 2012, the defendant did not accept any letter of demand to vacate the said premises, for the reason that he already leaved the said premises befor 15 March 2012; c) That an oral demand by the plaintiff has never been happened, for the reason that they did not see each other since he leaved the said premises.
  • 2. 5) That he is executing this Reply – Complaint to attest to the truth of the foregoing statements, and to move for the dismissal of the above case for lack of legal and factual basis. SUBSCRIBED AND SWORN TO before me this 27th day of August 2012, in the City of Baguio, Philippines ATTY. BJ MAYER (Attorney for Defendant)