REPUBLIC OF THE PHILIPPINES

7th JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH _____
CEBU CITY
JUAN DE LA CRUZ
Plaintiff,
-versus-

CIVIL CASE NO. ______________

FOR:

JUAN TAMAD
Defendant.
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MOTION TO DECLARE DEFENDANT IN DEFAULT
Plaintiff, by counsel and unto this Honorable Court, respectfully states
1. The records of the Honorable Court show that Defendant was served with copy of the
summons and of the complaint, together with annexes thereto on 15 January 2015.
2. Upon verification however, the records show that Defendant Juan Tamad has failed to
file his Answer within the reglementary period specified by the Rules of Court despite the
service of the summons and the complaint;
3. As such, it is respectfully prayed that Defendant Juan Tamad be declared in default
pursuant to the Rules of Court and that the Honorable Court proceed to render judgment
as the complaint may warrant.
P R AY E R
WHEREFORE, it is respectfully prayed that Defendant JUAN TAMAD be
declared in default pursuant to the Rules of Court and that the Honorable Court proceed
to render judgment as the complaint may warrant.
Other reliefs, just and equitable under the given circumstances, are likewise prayed for.
RESPECTFULLY SUBMITTED.
16 FEBRUARY 2015
CEBU CITY, PHILIPPINES.
(COUNSEL)

NOTICE OF HEARING
HON. CLERK OF COURT
BR. _______
Greetings.
Kindly the foregoing motion to the attention of the Honorable Court immediately upon
receipt thereof and set the same for hearing on 20 FEBRUARY 2015, 8:30 A.M.

ATTY. XYZ
Counsel for the defedants.
Please be notified that the foregoing motion will be set for hearing this 20 February 2015,
8:30 A.M.
COPY FURNISHED:
ATTY XYZ
RECEIVED BY: