Republic of the Philippines

Regional Trial Court

Branch 40, Quezon City

JUAN CRUZ,
Plaintiff,
Civil Case No. 2345
-versus- For: Sum of Money

JOSE MANZANO
Defendant.

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MOTION FOR NEW TRIAL

DEFENDANT, by counsel and to this Honorable Court, respectfully states:

1. Defendant received a copy of the decision, which held him liable for P2,000,000.00 with
legal interest thereon from date of the decision.

2. Due to sickness of his counsel and lack of notice to him and to defendant himself, defendant
failed to attend the pre-trial and as consequence, he was declared in default and plaintiff
was allowed to present his evidence ex part.

3. In support of this motion, defendant attaches herewith, as part hereof, his affidavit
supporting the accident or mistake and his good and valid defenses to defeat plaintiff’s
claim, as Annex “2”.

WHEREFORE, defendant prays that the decision be reconsidered, that he be granted new trial,
and thereafter a new judgment be rendered holding defendant free and harmless from any
liability and dismissing the complaint.

Quezon City, January 30, 2019.

ATTY. TEE
Counsel for Defendant
*Verification

*Jurat

*Notice of hearing