Reply Civil Case

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  REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT 7 th  Judicial Region Branch 50 Cebu City PSBANK, Plaintiff, -versus- Civil Case No. CEB 1234 For: Replevin/ Recovery of Personal Property JUAN VILLORDON Defendant. x--------------------/ REPLY PLAINTIFF , by counsel and unto this Honorable Court, most respectfully submits this Reply to Defendant’s Answer with Counterclaim, thus avers that: 1.   Defendant, in paragraphs 3, 4, and 5 of her Answer with Counterclaim, alleged that defendant's mode of payment of his car loan with the Plaintiff Bank has always been by way of auto-debit of his account with the same bank under Account No. 923 8758 287 and that payments have been made for months July to October 2017. It is noteworthy to point out that such allegation is not part of the Promissory Note and Chattel Mortgage and no such deposit slips were presented to the Bank Manager representing the bank corporation as proof of payment. Thus, defendant’s assertion that payments have been made has no basis. 2.   Defendant, in paragraphs 8, 9 and 10 of her Answer with Counterclaim, alleged that- “ Upon receipt of the said demand letter, Defendant immediately visited the Plaintiff's branch to complain about the said demand letter and to pay his amortization for November 5, 2017 over-the-counter and presented as proof of payment the bank deposits for the mentioned months due.”  The truth is that since year June 2017, plaintiff has already repeatedly reminded to faithfully comply with the payment terms and conditions of the Chattel Mortgage nonetheless,  he did not heed the reminders and defaulted on his payments for the months July to October 2017. 3.   Defendant’s claim for compensatory damages is baseless since the subject motor vehicle has never been seized by the bank. 4.   Defendant’s claim for moral damages is likewise unwarranted as plaintiff only sought judicial intervention. 5.   Defendant-debtor has, as of this date, still has not paid herein plaintiff a single centavo and defaulted in the payment of an aggregate amount of P250,000, causing the plaintiff severe damage and prejudice and loss of her hard-earned money;  WHEREFORE , premises considered, it is hereby respectfully   prayed that the foregoing Reply to Defendant’s Answer with Counterclaim  be   given due credence and consideration and the reliefs prayed for in the   Complaint be granted. Finally, Plaintiff respectfully prays for such and other reliefs as may be deemed just and equitable under the premises. May 19, 2018, Cebu City Philippines. SOON AND DIONALDO LAW OFFICES Counsel for the Plaintiff Governor M. Cuenco Ave., Banilad, Cebu City Tel. No. 032-4567890 By: SANDRA JANE N. SOON PET No. 12387654/January 03, 2018/Cebu Province IBP No. 3214567/December 15, 2017/Cebu City Roll No. 54764 MCLE Compliance No. V-0007865, 02/01/16
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