REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH ___
MANILA

JOE GRANA, Civil Case No. CV-2017-01

Plaintiff, FOR: COLLECTION OF SUM
OF MONEY WITH
DAMAGES
- versus -

JUAN JAMERO,
Defendant.
x -----------------------x

MOTION TO DECLARE DEFENDANT IN DEFAULT

Plaintiff, by counsel and unto this Honorable Court, respectfully

states that:

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 15 January 2015.

2. Upon verification however, the records show that Defendant

JUAN JAMERO 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 JUAN

JAMERO 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 JUAN

JAMERO 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.

RESPECTFULLY SUBMITTED.

Manila, March 26, 2018.

ATTY. LOVELY L. DE LA TORRE

De La Torre Law Office, 8th Floor,
Excelsior Bldg., Sampaloc, Manila
Roll of Attorneys No. 19283
PTR NO. 2651863, 05/17/17, Manila
IBP NO. 2122, 05/17/17, Manila
 NOTICE OF HEARING

HON. CLERK OF COURT

BR. _______

Greetings.

Kindly the foregoing motion to the attention of the Honorable Court

immediately upon receipt thereof and set the same for hearing on 20
FEBRUARY 2015, 8:30 A.M.

ATTY. XYZ
Counsel for the defedants.

Please be notified that the foregoing motion will be set for hearing this 20
February 2015, 8:30 A.M.

COPY FURNISHED:

ATTY XYZ

RECEIVED BY: