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
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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)