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 _____________;
2.Upon verification however, the records show that Defendant
_____________ 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 _____________ 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 _____________ be
declared in default pursuant to the Rulesof Court and that the Honorable
Court proceed to render judgment as the complaint may warrant.
Other relief just and equitable are likewise prayed for.
_____________, Philippines, __Date__.

(COUNSEL)

(NOTICE OF HEARING)
(EXPLANATION)

COPY FURNISHED:

OPPOSING COUNSEL