Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch_____, Manila
ALEXANDER SISON,
Plaintiff,
Civil Case No. 0002
For: Collection of Sum of
Money with Prayer For the
Issuance of Writ of
Preliminary Attachment

- versus -

JUAN JAMERO,
Defendant.
x ---------------------------------- x
MOTION TO DECLARE DEFENDANT IN DEFAULT
PLAINTIFF, by counsel, respectfully states that:
1. Plaintiff filed this Complaint against defendant on 1 st day of September 2009;
summons were served on defendant on 3rd day of September 2009, as
indicated by the Sheriffs Return of even date, a copy of which is attached as
ANNEX A;
2. Defendants reglementary period to file Answer ended on 18 th day September
2009; no motion for extension of such period was filed nor was any granted
motu proprio by this Honorable Court. Despite the lapse of time, defendant
has failed to answer the Complaint against him; plaintiff is entitled to a
declaration of default and the right to present evidence ex parte against
defendant;
3. That plaintiff has duly complied with the service of request and notice of
hearing and proof of personal service;
WHEREFORE, plaintiff respectfully prays that defendant be declared in default
and that plaintiff be allowed to present evidence ex parte before the Clerk of Court acting
as Commissioner.
Manila; 19th day of September, 2009.

ATTY. Mary JOY S. DEJADA

Counsel for the plaintiff
1234 suite Makat

NOTICE OF HEARING
THE BRANCH CLERK OF COURT
Regional Trial Court
Manila,
Mr. Juan Jamero
222 Juan Luna St.,Tondo Manila
Please submit the foregoing Motion to the Court for its consideration and
approval immediately upon receipt hereof and kindly include the same in the courts
calendar for hearing on Friday, 19 September 2009 at 8:30 in the morning.

Atty. Mary Joy S. Dejada

1234 suite, Makati Manila

Copy furnished through personal service:

Atty. Merriam D. Solis
Counsel for the Defendant
123 Building
Laguna Street, Quezon City
Received by:
Date:

ANNEX A
Republic of the Philippines
Regional Trial Court
National Capital Judicial Region
Branch______, Manila City
ALEXANDER SISON,
Plaintiff,
-

versus

JUAN JAMERO
Defendant.
x----------------------------------x

Civil Case No. ________

For: Sum of Money
with a writ of Preliminary attachment

SUMMONS
TO: Juan Jamero 222 Juan Luna St., Tondo Manila
GREETINGS:
You are hereby summoned and required to enter your appearance in the aboveentitled case within fifteen (15) days after the service of this Summons upon you,
exclusive of the day of such service, and answer the complaint of the plaintiff/s which is
hereto attached and herewith served upon you within the time fixed by the Revised
Rules of Court. If you fail to do so, judgment by default will be taken against you for the
relief prayed for in the complaint.
WITNESS THE HON. Parreno, Judge of this Court, this 3rd day of September, 2009.

FOR THE HONORABLE JUDGE:

Maerk L
MARK LOZANO
CLERK OF COURT