Forms Anscc Presentation

7/29/2019 Forms Anscc Presentation

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REPUBLIC OF THE PHILIPPINESNATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT

Quezon City

Branch 69

MICHAEL ROMERO,

Plaintiff,

-versus- CIVIL CASE NO. 12345-13

MARIO DINGLASAN,

Defendant,

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

ANSWER WITH AFFIRMATIVE DEFENSE AND

COUNTERCLAIM


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5. Defendant specifically denies under oath the allegation in paragraph14 of the complaint evidenced by Annex E, the truth being that,Defendant had already remitted to herein Plaintiff the entire Four

Million Pesos (P4,000,000) proceeds of the sale of the imported office

equipment on August 30, 2012. The acknowledgment receipt of the

said remittance is herein attach as Annex 2, and made integral parthereof;

6. Defendant specifically denies under oath the allegation in paragraph18 of the complaint, the truth being that, Defendant had already

returned to herein Plaintiff the Four Million Pesos (P4,000,000) worth

of unsold imported office equipment on December 1, 2012. Theacknowledgment receipt of the said return is herein attach as Annex

3, and made integral part hereof.

COUNTERCLAIM

1. That even after the Defendant has remitted Four Million Pesos(P4,000,000) to the Plaintiff, as the total amount of sale of theimported office equipment, the former has not received the five

percent (5%) of the total sales of the imported office equipment as hispayment which has been agreed on the Contract to Sell evidenced by

Annex A of the complaint, in the total amount of One Hundred


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

Quezon City, March 29, 2013

Alba Diaz Sibal Venus Law Offices

Counsel for the Defendant

No. 88 Arch. Bishop Reyes St.,

Pasig City

By:

ATTY. VERONICA DIAZIBP No. : 887302; 11/11/2011Manila

PTR No.: 42942; 11/11/2011ManilaRoll No.: 083614; 04/01/2010

MCLE No. I- 936424; 04/01/2010Contact Number: 557-8968 loc. 065

Email Address:[email protected]
mailto:[email protected]:[email protected]:[email protected]:[email protected]


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VERIFICATION

I, MARIO DINGLASAN, of legal age, Filipino citizen, single, after

having been duly sworn in accordance with law, depose and state that:

1. I have caused the preparation of the foregoing answer with defenses,and the allegations therein are true and correct of his personalknowledge and/or based on authentic records.

2. That he further states that acknowledgment receipt, Annex C of thecomplaint, is a forgery and his signature therein has been forged.

IN WITNESS WHEREOF, I have hereunto affixed my signaturethis ____ day of March2013, in the City of Quezon.

MARIO DINGLASANPlaintiff212 Sta. Maria St., Pasig City


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(REPUBLIC OF THE PHILIPPINES)

) S.S.

AFFIDAVIT OF SERVICE

I, UNCLE SAM, Filipino, of legal age, and with office address at 88

Bishop Reyes Street, Pasig City, under oath, do here by depose andstates that:

On, _______________, I caused the service of Answer in the case ofMichael Romero, Plaintiff vs Mario Dinglasan, Defendant, Civil

Case No. 12345-13; Regional Trial Court, Branch 69, Quezon Cityby registered mail:

GUARINO PACIENCIA SARMIENTO LAW OFFICECounsels for the Plaintiff

123 1st Floor, SM Old Building,Sta Mesa Manila


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PTR. No. 87654; 1/2/2012; Quezon City

Doc. No. _____;

Page No. _____;

Book No. _____;Series of 2013


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August 30, 2012

ACKNOWLEDGEMENT RECEIPT

Received from MARIO DINGLASAN the amountofFour Million Pesos (P4,000,000)BPI ShawBlvd., Pasig City Branch check # 12345-67890representing the payment of imported officeequipment.

Received by:

MICHAEL ROMERO

Witnessed by:


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December 1, 2012

ACKNOWLEDGEMENT RECEIPT

Received from MARIO DINGLASAN the importedoffice equipment in the amount ofFour MillionPesos (P4,000,000), which he agreed to sell inmy behalf. The said set of imported equipment iscomposed of the following:

1.250 pieces of complete (CPU, Monitor with built-incamera, Keyboard, Speaker, Optical Mouse, Printer withScanner) personal computer set, all with brand nameMacintosh;

2.250 pieces of complete (CPU, Monitor with built-incamera, Keyboard, Speaker, Optical Mouse, Printer withScanner) personal computer set, with brand nameHewlett-Packard;

3.250 pieces of LCD projector, with brand name Canon;4. 250 pieces of LCD projector, with brand name Sharp;


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INVENTORY OF SALE

DATE OF SALE NAME OF BUYER QUANTITY MERCHANDISE SOLD TOTAL AMOUNT OF PURCHASE

25-Mar-12 Accenture Philippines 200

Complete personal computer set, all with

brand name Macintosh (CPU, Monitor with

built-in camera, Keyboard, Speaker, Optical

Mouse, Printer with Scanner)

200


brand name Hewlett-Packard (CPU, Monitor

with built-in camera, Keyboard, Speaker,

Optical Mouse, Printer with Scanner)

100 LCD projector, with brand name Canon

100 LCD projector, with brand name Sharp

50 Photocopier, with brand name Canon

50 Photocopier, with brand name Sharp P2,000,000.00

1-Aug-12 Convergys Philippines 100





100


brand name Hewlett-Packard (CPU, Monitorwith built-in camera, Keyboard, Speaker,

Optical Mouse, Printer with Scanner)

50 LCD projector, with brand name Canon

50 LCD projector, with brand name Sharp

50 Photocopier, with brand name Canon

50 Photocopier, with brand name Sharp P1,000,000.00


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16-Aug-12

Accenture Philippines (on

credit; due on Sept. 1, 2012) 100





100


brand name Hewlett-Packard (CPU, Monitor

with built-in camera, Keyboard, Speaker,

Optical Mouse, Printer with Scanner) P1,000,000.00

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