REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF QUEZON CITY

National Capital Judicial Region
BRANCH 136

JON BATUMBAKAL,
Plaintiff,

Civil Case No. 2018-0516

FOR: COLLECTION OF
SUM OF MONEY

-versus-

CERSEI DATINGALING,
Defendant.

x--------------------------------------------------------x

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 25 April 2018.

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

Datingaling 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 Cersei Datingaling 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 CERSEI

DATINGALING 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 reliefs, just and equitable under the given circumstances, are likewise
prayed for.

Given this 16th day of May 2018 at Quezon City, Philippines.

BY:

ATTY. XERES ANNE C. CASTAÑEDA

Counsel for Plaintiff
LIFE MEMBER ROLL NO. 06420, 5 Jan 17, Quezon City
PTR NO. 5639729, 03 Jan 18, Quezon City
ROLL OF ATTORNEY NO. 44938
MCLE Comp. No C- 32257, valid until 20 April 19

NOTICE OF HEARING
HON. CLERK OF COURT
BR. 136

Greetings!

Kindly bring the foregoing motion to the attention of the Honorable Court
immediately upon receipt thereof and set the same for hearing on 20 th day of
May 2018, 8:30 A.M.

ATTY. XERES ANNE C. CASTAÑEDA

Counsel for Plaintiff
LIFE MEMBER ROLL NO. 06420, 5 Jan 17, Quezon City
PTR NO. 5639729, 03 Jan 18, Quezon City
Roll of Attorney NO. 44938
MCLE Comp. No C- 32257, valid until 20 April 19

Please be notified that the foregoing motion will be set for hearing this 20 th
day of May 2018, 8:30 A.M.

COPY FURNISHED:

ATTY. SHANTI LOPEZ

Counsel for the Respondent

Quezon City, Philippines