REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
BRANCH ______, _______________________

_______________________,
Plaintiff,

CIVIL CASE NO. ____

For: COLLECTION OF SUM OF
MONEY

_______________________
Defendant.
x--------------------------------------------x

MOTION TO RENDER JUDGMENT

Plaintiff thru counsel to this Honorable Court, most

respectfully states that:

1. On _______________, Plaintiff filed the above-entitled

case against Defendant with the Honorable Court, paying the
appropriate docket fees.

2. Summons and a copy of the complaint was finally

served unto the defendant on _______________________, thru
defendants daughter, _______________________, a person of
suitable age and dscretion. (Pls. see attached Summons and
Sheriffs Return of Summons, Annexes A and B,
respectively).

3. On _______________________, plaintiffs counsel inquired

with the office of this Honorable Court as to whether or not
defendant have already filed his Answer within the period
prescribed by Rules. Plaintiffs counsel was then told by the
person in-charge of civil cases that there is yet no Answer filed.

4. The reglementary period to answer has expired without

the defendant filing any answer.

5. For this reason, a judgment may now be rendered by

this Honorable Court motu proprio or upon motion of the
Plaintiff, as may be warranted by the facts alleged in the
Complaint and limited to what is prayed for therein.
 WHEREFORE, premises considered, it is respectfully
prayed for that judgment be rendered in favor of Plaintiff and
against the Defendant, ordering the Defendant to pay Plaintiff:

a. The amount of _______________________, representing

defendants indebtedness with legal interest from the date of
final demand;

b. The amount of _______________________as Attorney's

Fees plus Appearance Fee at the rate of
_______________________per court hearing;

c. The costs of suit.

Other reliefs just and equitable under the premises are

also prayed for.

RESPECTFULLY SUBMITTED.

Las Pias City, _______________________

_______________________
Counsel for the Plaintiff
MCLE No. _______________________; ____________
PTR No. ____________; Cavite; ____________
IBP No. ____________; ____________
____________________________________
____________, Las Pias City
Email: ________________________
Contact No.: ________________________

THE CLERK OF COURT

Metropolitan Trial Court
Las Pias City

G R E E T I N G S:

Please take notice that on ____________at 1:30 oclock in

the afternoon or soon thereafter as counsel and matter may be
heard, the undersigned counsel will move the Honorable Court
to grant the foregoing motion without further argument and
appearance.

________________________

Copy Furnished:

____________
________________________

EXPLANATION

Pursuant to Section 11, Rule 13 of

the 1997 Rules of Civil Procedure,

Due to lack of material time and absence of a messenger

to cause the personal service of this pleading, undersigned
counsel was constrained to serve a copy of the same by
registered mail to the defendant.

________________________