REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
METROPOLITAN TRIAL COURT
CITY OF MAKATI
BRANCH 66
UCPB GENERAL INSURANCE
COMPANY, INC.
Plaintiff/s,
- versus - CIVIL CASE No. 111484
FOR: Sum of Money
NOEL ANONUEVO,
Defendant/s.
x ------------------------------------------ x
ANSWER
(with Motion for Leave of Court to file Third Party Complaint)
DEFENDANT, by himself, respectfully states that:
ADMISSIONS/SPECIFIC DENIALS
1. He admits the contents of paragraphs 1, 2, 3, 4, 9, 10, 11;
2. He admits the contents of paragraph 5 only insofar as to the time, date,
location of the accident, personal circumstances of the owners/drivers of
the involved vehicles but he specifically denies that he failed to apply his
brakes. Defendant, upon approaching was slowing down already when
another approaching car driven by Peter John V. Ranero, hit the rear-end
of his vehicle;
3. He specifically denies the contents of paragraphs 6 and 7 for the reason
that he exercised the required diligence for private vehicle drivers, which
is the diligence of a good father. But because of the strong impact
brought about by the rear-end crash, defendant’s slow-approaching
vehicle was pushed forward and caused it to hit the rear-end of the
vehicle in front of him, which consequently resulted to that front vehicle
hitting the rear-end of plaintiff’s vehicle;
4. He admits the contents of paragraph 8 only insofar as the vehicular
incident was investigated but he denies the findings contained in the
Traffic Accident Report Form attached as Annex “H” for the reason
stated in the preceding paragraph;
5. He specifically denies the contents of paragraph 12 for the reason stated
in herein paragraph 3;
6. He specifically denies the contents of paragraphs 13 and 14 for the reason
that he never received any demand letter from the plaintiff.
WHEREFORE, for the reasons stated, defendant respectfully prays
unto this Honorable Court to give him twenty (20) days leave of court to
file the necessary third party complaint against PETER JOHN V.
RANERO, the driver of vehicle 5 as described and identified from the
Traffic Incident Sketch Form, Annex “J”, and to send notices to the
driver and/or owner of the said vehicle.
Other reliefs, just and equitable, are likewise prayed for.
Respectfully submitted.
4 May 2015, Makati City.
Assisted by:
PUBLIC ATTORNEY’S OFFICE
Department of Justice
16th Floor, Makati City Hall
J.P. Rizal St., Poblacion, Makati City
Atty. Antonio Francis G. Chua
Counsel for the defendant
Public Attorney I
Roll of Attorney No. 63101
Lifetime IBP No. 013232; Makati City
MCLE Compliance not yet applicable
NOTICE OF HEARING
Atty. Jerome B. Aragones
Counsel for: UCPB GENERAL INSURANCE CO., INC.
RINT Bldg., 3rd Flr, Block 1,
Lot 8, Gold Avenue, Phase 4,
Maryhomes Subd., Molino IV,
Bacoor City, Cavite
Sir:
Please be informed that the undersigned counsel has set the foregoing
motion for hearing on _________________ at ________ for the consideration of
the Honorable Court or soon thereafter as counsel may be heard.
Atty. Antonio Francis G. Chua
Copy furnished:
PERLITA C. ORDINARIO
Branch Clerk of Court
Metropolitan Trial Court
Makati City
Branch 66
ATTY. JEROME B. ARAGONES
Counsel for the Plaintiff
RINT Bldg., 3rd Flr, Block 1,
Lot 8, Gold Avenue, Phase 4,
Maryhomes Subd., Molino IV,
Bacoor City, Cavite
