COMES NOW the defendant, by undersigned counsel, and in answer to plaintiff's complaint, respectfully alleges:

      1. That defendant admits paragraphs _________ and _____________ of the complaint;

      2. That defendant is without knowledge or information to form a belief as to the truth of the averments made in paragraphs ______ and _______ thereof;

      3. That defendant DENIES specifically each and every material allegations made in paragraphs ______ and ______ of the complaint, and alleges that (here state the substance of the matters which defendant will rely upon to support such specific denial);

      4. And as AFFIRMATIVE DEFENSES, the defendant alleges:

           A. That (here state as many affirmative defenses as defendant may have. All such grounds as would raise issues of facts not arising upon specific denials must be specifically pleaded.which may have basis in the provisions of STATUTE OF LIMITATIONS, STATUTE OF FRAUDS, ESTOPPEL, RELEASE OR DISCHARGE, ETC.)

           B. That (state other defenses):

      5. As COUNTERCLAIM against the plaintiff, the defendant alleges:

           A. That defendant reproduces paragraphs ____- of the plaintiff's complaint;

           B. That (state defendant's claim for money or other relief which he may have against the plaintiff; such counterclaims need not diminish or defeat the recovery sought by the plaintiff, but may claim relief exceeding in amount or different in kind from that sought by the plaintiff, provided that the court has jurisdiction to entertain the claim);

      WHEREFORE, it is respectfully prayed that:

           (a) Prayer (for judgment in favor of defendant with respect to plaintiff's complaint);

           (b) Prayer (for judgment in favor of defendant with respect to counterclaim); and

           (c) For such other relief consistent with law and equity, and for costs.

      Quezon City, _______________, 2004