Republic of the Philippines

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Branch LXII (62)
Makati City

AMER KADO,
Plaintiff,

- versus -
Civil Case No. 111222

KARLA BAN,
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 Maka 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.

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

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

Makati City, Philippines. August 5, 2013.

 ATTY. BEN TONG
Counsel
for Defendant

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

MeTC - Branch 62
Makati City

ATTY. BEN TAMBLING

Counsel for the Plaintiff
1234 Zamora Street, Pasay City

Greetings!

Please take notice that the undersigned counsel will submit the
foregoing Motion to the Honorable Court on August 27, 2013 at 8:30 in the
morning for its favorable consideration and approval.

BEN TONG

Copy furnished by registered mail:

ATTY. BEN TAMBLING

Counsel for the Plaintiff
2233 Zamora Street, Pasay City

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.

BEN TONG