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Republic of the Philippines

REGIONAL TRIAL COURT


National Capital Judicial Region
City of Manila, Branch ________

ANNE GAZA,

Plaintiff,
Civil Case No.__________
-versus- For: Collection for Sum of
Money with Prayer for Pre-
liminary Attachment
CHRISTINE GAPOR

Defendant.

X------------------------------------------------X

COMMENT/OPPOSITION TO DEFENDANT’S MOTION FOR RE-


CONSIDERATION TO LIFT ORDER OF DEFAULT AND EXTEN-
SION OF TIME TO FILE ANSWER

COMES NOW, Plaintiff through undersigned counsel and unto


this Honorable Court, most respectfully submits this Comment/Oppo-
sition to the Defendant’s Motion for Reconsideration and states that;

1. On June 22, 2018, Plaintiff received a copy of the Motion for


Extension of Time filed by herein Defendant seeking to extend
the time to file her answer on the ground that her counsel has
other equally important cases to attend to;

2. Clearly, this premise lacks basis and is only intended to delay


the case.

3. Considering the foregoing, it is respectfully prayed that the Mo-


tion for Extension of Time to File Answer be denied and defend-
ant Christine Gapor be declared in default pursuant to the Rules
of Court for failure to file an Answer beyond the Reglementary
period. It is further prayed for that this Honorable Court proceed
to render judgment as the complaint may warrant of if this hon-
orable Court will require, direct the Plaintiff to present evidence
ex-parte in support of its Complaint.

PRAYER
WHEREFORE, it is respectfully prayed that the that the Motion
for Extension of Time to File Answer be denied and defendant Chris-
tine Gapor be declared in default pursuant to the Rules of Court for
failure to file an Answer beyond the reglementary period. It is further
prayed for that this Honorable Court proceed to render judgment as
the complaint may warrant of if this honorable Court will require, direct
the Plaintiff to present evidence ex-parte in support of its Complaint..
Plaintiff prays for such other reliefs as may be just and equitable
in the premises.

Pasig City for Makati City, June 24, 2018.

BUERGO & CABATBAT LAW OFFICE


Counsel for Plaintiff Anne Gaza
Unit 1102 The Centerpoint Building
Julia Vargas Ave. cor. Garnet Rd., Ortigas Center
Pasig City, Philippines 1605
P.O. BOX 12888, Ortigas CPO
(+632) 638 7265 www.buergocabatbat.org

By:

RHOWEE BUERGO
Roll of Attorneys No. 57270
IBP Lifetime Member Roll No. 08328, 04-21-2018
PTR No. 2507681, 01-03-2018, Manila City
MCLE Compliance No. V-0021078, 05-05-2018
Email: rbuergo.rb@gmail.com

And

PIA CABATBAT
Roll of Attorneys No. 67270
IBP Lifetime Member Roll No. 09328, 04-21-2018
PTR No. 2507681, 01-03-2018, Manila City
MCLE Compliance No. V-1121078, 05-05-2018
Email: piacabatbat@gmail.com

Copy furnished by Personal service on June 24, 2018:


Atty. Doris Gallardo
Atty. Patricia Huevos
Counsel for Defendant