Prepare:
Answer that will merit the grant of a motion for judgment on the pleadings
Motion for summary Judgment for claimant
Motion for Summary judgment for the defending party
Case:
January 18: ABC Corp with Susan Navarro (officer and stockholder), filed an application for loan (Php
10M) with Rural Bank under government’s guarantee fund for small and medium enterprises
As security for the loan, Susan along with Jayson Ramos and George Carlos executed deeds of suretyship
in favor of the bank
Loan was granted
ABC defaulted in the payments of its obligation to bank; bank foreclosed the mortgage
Proceeds was Php 6M
Bank filed an action to recover the remaining balance of the entire obligation including interests,
penalties and other charges, exemplary damages and attorney’s fees against Susan and her companions
Susan and her companions filed their joint answer with counterclaim denying personal liablity saying
they merely accommodated ABC