REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES
CITY OF SAN JOSE DEL MONTE
PROVINCE OF BULACAN
BRANCH 2

JOSE RAMON A. RAMOS, and

MANUEL ANTONIO A. RAMOS,
Plaintiffs,
CIVIL CASE NO. 033-SJ-2016
FOR: RECOVERY OF POSSESSION
ESTELLA CERCENIA,
JOSE LEGASPI JR.,
ALEX OSORIO, and
SOPHIA FLORES,
And all persons claiming rights
Under their names,
Defendants.
x------------------------------------x

MOTION
(TO DECLARE DEFENDANT IN DEFAULT)

Plaintiffs, by counsel and unto this Honorable Court, most respectfully states that:
1. The records of the Honorable Court show that Defendant JOSE LEGASPI JR. was
served with copy of the summons and of the complaint, together with annexes
thereto on January 26, 2017;

2. Upon verification however, the records show that Defendant JOSE LEGASPI JR. has
failed to file his Answer within the reglementary period specified by the
Rules of Court1 despite the service of the summons and the complaint;

3. As such, it is respectfully prayed that Defendant JOSE LEGASPI JR. be declared in

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

PRAYER

WHEREFORE, it is respectfully prayed that Defendant JOSE LEGASPI JR. 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 relief just and equitable are likewise prayed for.

City of San Jose del Monte, Bulacan. 13 March 2017.

1
Sec. 3, Rule 9.
 WARLITO DM. GOGOLIN
Poblacion I, City of San Jose del Monte, Bulacan
Roll NO. 52714
IBP No. 1040913/1-3-2017; Bulacan
PTR No. 1452998/1-3-2017; CSJDM, Bulacan
MCLE Compliance V No. 0000433/8-29-13

NOTICE OF HEARING WITH EXPLANATION

BRANCH CLERK OF COURT

MTCC Branch 2
City of San Jose del Monte
Bulacan

JOSE LEGASPI JR.

Blk 11, Lot 2A, Brgy. Gumaok West,
CSJDM, Bulacan

Greetings!

Please submit the foregoing motion for consideration and approval of the Honorable
Court on _______________ at 8:30 in the morning, or at the time most convenient to the
calendar of the Honorable Court.

A copy of this Motion was not served personally to above-named private complainant
for lack of personnel to do the same, copy of which was served to him by registered mail
with return card.

WARLITO DM. GOGOLIN