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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


MANILA

PEOPLE OF THE PHILIPPINES,


Complainant,
Criminal Case No. 2312
-versus-
For: Parricide
A,
Accused.
x-------------------------------------------x

ANSWER WITH AFFIRMATIVE DEFENSE


NOW COMES the accused in the above titled case, and to this
Honorable Court most respectfully alleges:
1. That the accused specifically denies that he killed B willfully and
feloniously;
2. That it was B who first attacked the accused during their heated
argument;
3. That B was able to get a hold of a knife and attempted to stab the
accused;
4. That the accused was able to dodge the same, and was able to get
his gun only to frighten B so that she would stop;
5. That the accused accidentally pulled the trigger and shot B leading
to her death.
By way of affirmative defense, accused avers:
1. That the unintentional killing of B was self-defense

WHEREFORE, it is respectfully prayed that the information be dismissed.

Other equitable reliefs are likewise prayed for.

Manila, Philippines, November 28, 2020.

ATTY. LAURO GUERRERO


Counsel of Defendant
PTR No. 333 / 01-06-2020 / Manila
IBP LRN 222 / 1-16-2020 / Manila
Roll of Attorneys 99
MCLE Exemption no. III-99
EXPLANATION
Copy of this pleading was sent to the opposing counsel through registered
mail as personal service is impracticable.

Manila, Philippines, November 28, 2020.

Copy Furnished:

ATTY. ALLEN MARIE


Unit 2311, 23rd Floor Herrera Tower
Valero corner V.A. Rufino Sts.
Salcedo Village, City of Makati

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