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Republic of the Philippines

REGIONAL TRIAL COURT


6th Judicial Region
Branch No. 32
Iloilo City

ANGEL C. LOCSIN,
Plaintiff,

- versus -
Civil Case No. 2017-34

JESSY M. MENDIOLA,
Defendant.
x-------------------------------------------x

MOTION TO INHIBIT

DEFENDANT, through the undersigned counsel, respectfully


moves this Honorable Court to desist from trying the above-entitled
case on the following averments:

1. That defendant has been summoned before this Honorable Court;

2. That it appears that there is danger of partiality, bias and prejudice in


favor of the plaintiffs for the reason that Honorable Judge Demaka
Tarungan is related to the plaintiff within the 4th civil degree of
consanguinity;

3. That defendant will be prejudiced if the Honorable Judge continues to


hear the above-entitled case;

4. That it is necessary that the Honorable Judge inhibit himself so as to


promote the administration of justice.

PRAYE R

WHEREFORE, in view of the foregoing, it is respectfully prayed


that Honorable Judge Demaka Tarungan inhibit himself from hearing
and trying the above-entitled case.

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Iloilo City, Philippines. January 23, 2017.

SHANE MARIE BELLOGA - EDROSOLANO


Counsel for the Defendant
Arguelles Bldg., Jaro, Iloilo City
Roll No.: 110928
PTR No.: 1112345 06-30-2016 Iloilo City
IBP No.: 176184 06-30-2016 Iloilo City
MCLE Compliance No.: 455813 08-05-2016

NOTICE OF HEARING

THE BRANCH CLERK OF COURT


RTC - Branch 32
Iloilo City

ATTY. MAYEN MAR E. GULMATICO


Counsel for the Plaintiff
Gulmatico Bldg., Janiuay, Iloilo

Greetings!

Please take notice that the undersigned counsel will submit the
foregoing Motion to the Honorable Court on January 25, 2017 at 8:30
in the morning for its favorable consideration and approval.

SHANE MARIE BELLOGA - EDROSOLANO

Copy furnished by registered mail:

ATTY. MAYEN MAR E. GULMATICO


Counsel for the Plaintiff
Gulmatico Bldg., Janiuay, Iloilo

EXPLANATION

Due to lack of messengerial services to effect personal service,


a copy of the foregoing motion was sent to defendant's counsel
through registered mail.

SHANE MARIE BELLOGA - EDROSOLANO

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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 _____________;

2. Upon verification however, the records show that Defendant 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 _____________


be declared in default pursuant to the Rules of Court and that the
Honorable Court proceed to render judgment as the complaint may
warrant.

PRAYE R

WHEREFORE, it is respectfully prayed that defendant


_____________ be declared in default and that judgment be
rendered against said defendant, granting all the reliefs prayed for in
the complaint.

Other relief just and equitable are likewise prayed for.

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Iloilo City, Philippines, __Date__.

SHANE MARIE BELLOGAEDROSOLANO

Arguelles Bldg., Jaro, Iloilo City


Roll No.: 110928
PTR No.: 1112345 06-30-2016 Iloilo City
IBP No.: 176184 06-30-2016 Iloilo City
MCLE Compliance No.: 455813 08-05-2016

NOTICE OF HEARING

THE BRANCH CLERK OF COURT


RTC - Branch 32
Iloilo City

ATTY. MAYEN MAR E. GULMATICO


Opposing Counsel
Gulmatico Bldg., Janiuay, Iloilo

Greetings!

Please take notice that the undersigned counsel will submit


the foregoing Motion to the Honorable Court on January 24, 2013 at
8:30 in the morning for its favorable consideration and approval.

SHANE MARIE BELLOGA - EDROSOLANO

Copy furnished by registered mail:

ATTY. MAYEN MAR E. GULMATICO

4
Opposing Counsel
Gulmatico Bldg., Janiuay, Iloilo

EXPLANATION

Due to lack of messengerial services to effect personal service,


a copy of the foregoing motion was sent to defendant's counsel
through registered mail.

SHANE MARIE BELLOGA - EDROSOLANO