This document contains the answer filed by Virginia Wang, the defendant, in response to a civil case for unlawful detainer brought against her by Margarita Ynares, the plaintiff. The defendant admits some facts of the complaint through her attorney Toby Emerson Pavon, such as the circumstances of the parties and the existence of a lease agreement. However, the defendant specifically denies that she was not willing to renegotiate the lease terms. The defendant requests that the case be dismissed for lack of cause of action and any other relief deemed appropriate by the court.
This document contains the answer filed by Virginia Wang, the defendant, in response to a civil case for unlawful detainer brought against her by Margarita Ynares, the plaintiff. The defendant admits some facts of the complaint through her attorney Toby Emerson Pavon, such as the circumstances of the parties and the existence of a lease agreement. However, the defendant specifically denies that she was not willing to renegotiate the lease terms. The defendant requests that the case be dismissed for lack of cause of action and any other relief deemed appropriate by the court.
This document contains the answer filed by Virginia Wang, the defendant, in response to a civil case for unlawful detainer brought against her by Margarita Ynares, the plaintiff. The defendant admits some facts of the complaint through her attorney Toby Emerson Pavon, such as the circumstances of the parties and the existence of a lease agreement. However, the defendant specifically denies that she was not willing to renegotiate the lease terms. The defendant requests that the case be dismissed for lack of cause of action and any other relief deemed appropriate by the court.
This document contains the answer filed by Virginia Wang, the defendant, in response to a civil case for unlawful detainer brought against her by Margarita Ynares, the plaintiff. The defendant admits some facts of the complaint through her attorney Toby Emerson Pavon, such as the circumstances of the parties and the existence of a lease agreement. However, the defendant specifically denies that she was not willing to renegotiate the lease terms. The defendant requests that the case be dismissed for lack of cause of action and any other relief deemed appropriate by the court.
BRANCH 6 CITY OF TAGAYTAY Mrs. Margarita Ynares, plaintiff - Versus
Civil Case No.003
for: Unlawful Detainer
Virginia Wang, Defendant
Accompanied by her attorney-in-fact Atty. Toby Emerson T. Pavon x----------------------------------------------x ANSWER HERE, the plaintiff together with undersigned counsel brings to this most honorable court, TO MOST RESPECTFULLY STATE THAT; 1. That she admits paragraph 1 as to the personal circumstances of both parties. 2. That she admits paragraph 2 as to the ownership of the Plaintiff over the property and paragraph 3 as to the existence of the said lease agreement. 3. That she specifically denies paragraph 8 in that Defendant was made to believe that Plaintiff would consider a renegotiation of the lease agreement and that she would continue to lease the property in the mean time. 4. That the Defendant denies paragraph 12 that any attempts were made by Plaintiff to reoccupy the manor as both parties have already begun re-negotiations of a new lease agreement for the property. PRAYER WHEREFORE, premises considered, it is respectfully prayed to this Honorable Court that the case be dismissed for lack of cause of action. Such other reliefs and remedies under the premises are likewise prayed for. City of Tagaytay, Philippines, this April 1, 2015 Toby Emerson Pavon Counsel for the Plaintiff PTR No. 1654891:7-09-06:B.C. IBP No. 549621:7-09-06:B.C.
Roll No. 6546216:7-30-99: Manila
1 Infinite Loop Drive, Paco Building Paco, Manila VERIFICATION AND CERTIFICATION I, Ms. Virginia Wang, of legal age, single, a Filipino citizen and a resident of Pasay, after being sworn according to law, hereby depose and state that: 1. I am the Defendant in this proceeding. 2. I have read and understood the filed complaint and the allegations therein. Virginia Wang Defendant In witness thereof, I, Mr. Toby Emerson Pavon, counsel of the plaintiff, have hereby set my hand this 1st day of April, 2015, at the City of Tagaytay. Toby Emerson Pavon Counsel for the Defendant PTR No. 1654891:7-09-06:B.C. IBP No. 549621:7-09-06:B.C. Roll No. 6546216:7-30-99: Manila 1 Infinite Loop Drive, Paco Building Paco, Manila
Copy furnished to Atty. John Doe, counsel for Plaintiff.
Served personally to and received by Atty. John Doe.