Posted by: Elmer Brabante | February 19, 2011

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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION

BRANCH _______, MANILA 

FIRST AFFAIRS, INC.,

Plaintiff,

– versus –                                                               CIVIL CASE NO. 12345 

FIVE CLASS PRODUCTS

COMPANY, INC., ET AL.,

Defendants.

x—————————————x 

R E P L Y 

            COMES NOW plaintiff, by its undersigned attorneys, and by way of reply to defendants’ Answer, to this Honorable Court, respectfully states:

I

            Defendant partner AAA did not negotiate with plaintiff company in June, 2008 but defendants BBB and/or the late CCC who tried to negotiate from time to time with plaintiff company;

II

            Plaintiff did not agree verbally or in writing to accept the mortgaged properties of defendant partner BBB as full payment of the principal obligation contained in the promissory note subject matter of the complaint;

III

            Plaintiff is not willing to accept the mortgaged propertied of defendant partner BBB in full satisfaction of the obligation of the defendants in the amount of P35,000.00;

IV

            There has been no novation of defendants’ obligation.

            WHEREFORE, it is respectfully prayed that judgment be rendered according to the prayer of the complaint.

            Manila, February 2011. 

                                                                                      EEE, FFF, GGG and HHH

                                                                        By:

                                                                                      APOLINARIO B. BRAVO

                                                                                      Attorneys for the Plaintiff

                                                                                      (Address)

Copy furnished:

                ATTY. BBB

     Counsel for the Defendants

             (Address)

By: _______________________

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