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1) Nena Rose Bugrong took out a loan of 50,000 pesos from Roshan Lanes Tagalibod and signed a promissory note with 30% interest and penalty for late payments. 2) Bugrong denies receiving full payment and claims receipts submitted by Tagalibod were obtained fraudulently. 3) Bugrong rejects Tagalibod's claims that the case constitutes unjust enrichment, and is simply asking for equitable repayment of the loan based on the terms of the promissory note. 4) Bugrong denies all other claims made by Tagalibod in their answer.

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2K views2 pages

REPLY Final Legal Form

1) Nena Rose Bugrong took out a loan of 50,000 pesos from Roshan Lanes Tagalibod and signed a promissory note with 30% interest and penalty for late payments. 2) Bugrong denies receiving full payment and claims receipts submitted by Tagalibod were obtained fraudulently. 3) Bugrong rejects Tagalibod's claims that the case constitutes unjust enrichment, and is simply asking for equitable repayment of the loan based on the terms of the promissory note. 4) Bugrong denies all other claims made by Tagalibod in their answer.

Uploaded by

Juris Poet
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


SIXTH JUDICIAL REGION
BACOLOD CITY, BRANCH IX
NENA ROSE Z. BUGRONG
Plaintiff
versus

CIVIL CASE NO. 12345566


FOR: Collection of a Sum of Money

ROSHAN LANES TAGALIBOD


Defendant
xx

REPLY
I, Nena Rose Bugrong, in my own behalf, respectfully submit
hereunder my reply to the Answer of the defendant Roshan Lanes
Tagalibod, to wit:
By way of Reply to Defendants Answer:
The Petitioner admits the content of Paragraph 1 of the
answer insofar as the contracting of a loan amounting to Fifty
Thousand Pesos (P50,000.00) and the existence of promissory
note for the payment of such loan.
That the Petitioner specifically denies the content of
Paragraph 2 that she had made a complete payment in the
amount of P50,000.00 evidenced by the receipt annexed herein.
Such receipt presented were obtained
fraudulently by the
defendant.
The content of paragraph 3 of the answer is likewise denied,
It is clear from the foregoing promissory note annexed herein that
in the event that the borrower fails to pay on the due date, 30 %
will accrue as an interest and another 30% will accrue as a
penalty which amounts to a total of 60% annually.
With respect to paragraph 4 of the answer the same is
likewise rejected, the defendant herself have received the
demand letters evidenced by a return copy, signed by her and
attached herein as annexedC.

With respect to the allegation of the defendant that the this


action constitutes as unjust enrichment, the same should be
rejected. Unjust enrichment is committed when a person is
unjustly enriched at the expense of another, in our case, were
simply asking for equity.
The rest of the allegations is denied for lack of information or
knowledge sufficient to form a reasonable belief thereof.
P R AYE R
WHEREFORE, in view of the foregoing, Defendants most
respectfully pray for the dismissal of the complaint and the award
of counterclaim to them. Other reliefs are likewise prayed for.

ATTY. CARLO FRANCES E. CABALLERO


Counsel for the plaintif
NOBC Bldg., Gatuslao St., Bacolod City
Attorneys Roll No. 098532
IBP No. 24525-01/03/15-Bacolod
PTR No. 53532- 01/03/15-Bacolod
MCLE Compliance No. IV-0012345 November 17, 2014

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