REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

12th JUDICIAL REGION
BRANCH 2
ILIGAN CITY

BORROWER ME
Plaintiff,

-versus- CIVIL CASE NO. 12345

FOR: COLLECTION OF SUM OF

MONEY

PALAUTANG XA
Defendant.
x---------------------------------------/

MOTION FOR RECONSIDERATION

Defendant, by counsel, most respectfully states:

1. DEFENDANT WAS DECLARED TO BE IN DEFAULT on

December 29, 2015 when he failed to file his answer within the
reglementary period. Herein attached as Annex 1 is the said order.

2. Defendant seeks for a reconsideration of the said Order for the reason
that he did not receive a copy of the complaint nor any summons from this
Honorable Court regarding the case above. He only received on February 1,
2016 a copy of the Order dated December 29,2015, already declaring him in
default.

3. In the interest of the substantial justice and for the reason earlier stated,
defendant begs this Honorable Court to try the case base on its merit as
delay in the proceedings of this case was never intended.

PRAYER

WHEREFORE, it is respectfully prayed of this Honorable Court to set

aside the Order of Default dated on December 29, 2015.
Other reliefs, just and equitable under the given circumstances, are likewise
prayed for.

Given this 4th day of March 2016 at Tibanga, Iligan City.

ATTY. ABOGADO TALAGA

Counsel for Defendant
IBP NO. 00107143, 1/02/17, Iligan City
PTR NO. 4899062143, 1/02/17, Iligan City
ROLL ATTORNEY NO. 15866143
MCLE Comp. No III- 00189143, 1/02/16
REQUEST FOR & NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Municipal Trial Court in Cities
Iligan City, Branch 2

Please submit the foregoing Motion to the Court for consideration and
approval immediately upon receipt hereof and kindly include the same in the
court’s calendar for hearing on 20th day of March 2016 at 10:00 in the
morning.

ATTY. ABOGADO TALAGA

Counsel for Defendant
IBP NO. 00107143, 1/02/17, Iligan City
PTR NO. 4899062143, 1/02/17, Iligan City
ROLL ATTORNEY NO. 15866143
MCLE Comp. No III- 00189143, 1/02/16

COPY FURNISHED:

ATTY. ATORNI TALAGA

Counsel for Defendant
IBP NO. 00107143, 1/02/17, Iligan City
PTR NO. 4899062143, 1/02/17, Iligan City
ROLL ATTORNEY NO. 15866143
MCLE Comp. No III- 00189143, 1/02/16

RECEIVED BY:

ATTY. ATORNI PO
Counsel for Plaintiff
IBP NO. 001071431, 1/02/17, Iligan City
PTR NO. 48990621431, 1/02/17, Iligan City
ROLL ATTORNEY NO. 158661431
MCLE Comp. No III- 001891431, 1/02/16

Iligan City, Philippines