REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF MANILA

1st JUDICIAL REGION
BRANCH 16
MANILA

ALEXANDER D. GREATEST,
Plaintiff.

CIVIL CASE NO. ____

---versus --- For: Collection of Sum
of Money

JUAN P. MASIPAG
Defendant.
x---------------------------------x

MOTION TO DECLARE DEFENDANT IN DEFAULT

PLAINTIFF, through her counsel and unto this Honorable Court

respectfully states:

Defendant was served with summons on March 13, 2017, as shown by

the return of the sheriff, attached to the court records, notwithstanding which
defendant failed to file his answer to the complaint within the 15-day period
therefrom.

WHEREFORE, plaintiff prays that defendant be declared in default

and plaintiff be authorized to present his evidence, ex parte, before the clerk
of court on such date as may be fixed, after which judgment be rendered
against defendants, as prayed for in the complaint.

Iloilo City, Philippines, April 12, 2017.

NONITO Q. PASUELO, JR.

Counsel for Plaintiff
Suite 007, 2nd Floor, Pasuelo Tower
MEGAWORLD, Iloilo City
Roll No. 66199
IBP No. 011 Lifetime
PTR No. 70 - 1/2/16 Iloilo
MCLE Compliance IV No. 001234
Issued on January 12, 2015

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 Notice of Hearing

Atty. Moana Maui

Counsel for the Defendant
16th Floor, INJAP Building,
Mandurriao, Iloilo City

Maam:

Please be informed that the undersigned counsel has set the foregoing
motion for hearing on April 18, 2017 at 8:30 a.m. for the consideration of
the Honorable Court or soon thereafter as counsel may be heard.

NONITO Q. PASUELO, JR.

Counsel for the Plaintiff

COPY FURNISHED THROUGH REGISTERED MAIL

ALEXANDER D. GREATEST
No. 112 Liberty Street,
Tondo Manila

ATTY. MOANA MAUI

16th Floor, INJAP Building,
Mandurriao, Iloilo City
Roll of Attorney No. 125485
IBP NO. 369582 / Mar 18, 2015/ Iloilo City
PTR NO. 398725/ Apr 29, 20115, Iloilo City
MCLE Compliance No. III-123, 1/3/2015

EXPLANATION

The foregoing pleading was served through registered mail due to

constraints in time, distance and lack of manpower to effect personal service
in Iloilo City.

NONITO Q. PASUELO, JR.

Counsel for the Plaintiff

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