Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Branch 03
Cebu City

PJH LENDING CORPORATION,

Plaintiff,
Civil Case No. R-55721
-versus- FOR: Collection of Sum of Money

MA. VICTORINA DIOLA,

Defendant.
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MOTION TO RENDER JUDGMENT ON THE PLEADINGS

PLAINTIFF, through the undersigned counsel unto the Honorable Court, most
respectfully alleges that:

1. On November 11, 2010, Plaintiff filed the above-entitled case against Defendant with
the Honorable Court, paying the appropriate docket fees;

2. Summons and a copy of the complaint was finally served unto the defendant on
December 1, 2010, thru defendant’s daughter, VICTORIA DIOLA-RAMA, a person
of suitable age and discretion. Hereto attached are the Summons and Sheriff’s
Return of Summons which are marked as Annexes “A” and “B”, respectively, by
reference;

3. Defendant filed her Answer dated December 15, 201o and hereby admitted the
following, to wit:

“3. That it is true that I and my son had borrowed money from the private
complainant sometimes on August 27, 2002 and which borrowed money was
used by my son, Reynaldo A. Go, Jr. in connection with the latter application for
work in the Middle East;
xxx xxx
7. Considering that I also signed the promissory note, I will be obliged to pay the
balance of the indebtedness with private complainant;

8. That it is not my desire nor the desire of my son not to pay our indebtedness
with private complainant;”

4. Considering that the accused has expressly admitted the substantial allegations
in the complaint with respect to their outstanding monetary obligation with the
complainant corporation, it is humbly moved by the latter that judgment be
rendered based on the said admission.

WHEREFORE, in view of the attendant circumstances, it is most respectfully prayed of

the Honorable Court to grant this motion and render Judgment on the civil aspect of the case in
favor of the plaintiff in view of the express admissions of the accused on the allegations in the
Complaint.
 Other just and equitable reliefs are likewise prayed for.

Cebu City, Philippines. January 28, 2010.

LEILANI TRINIDAD L. VILLARINO

Counsel for Plaintiff
PJH, Units 17-21
Century Plaza Commercial Complex
Juana Osmena, Cebu City
PTR No. 6409542, 1/07/10 Cebu
IBP No. 779442, 1/07/10 Cebu City
Attorney Roll No. 47710
MCLE Compliance No. III - 0000753

REQUEST and NOTICE

Mr. JOSE CELESTINO E. ACEVEDO
OIC Branch Clerk of Court
MTCC 3 Cebu City

Dear mr. Acevedo;

GREETINGS!

Kindly submit the foregoing Motion to the Honorable Court on February 5, 2010 at 8:30
o’clock in the morning for its approval and consideration sans further arguments and presence
of the undersigned.

LEILANI T. L. VILLARINO
Ms. MA. VICTORINA A. DIOLA
Old Railway, Inayawan
6000 Cebu City

Dear Ms. Diola;

Please take notice that the foregoing Motion will be submitted to the Honorable Court
on February 5, 2010 at 8:30 o’clock in the morning for its approval and consideration sans
further arguments and presence of the undersigned.

LEILANI T. L. VILLARINO
Copy furnished:

Ms. MA. VICTORINA A. DIOLA

Old Railway, Inayawan
6000 Cebu City

CERTIFICATION/EXPLANATION

Albeit the 1997 Rules of Civil Procedure, Section 11, Rule 13 thereof, provides that
whenever practicable, the service of pleadings and other papers shall be done personally,
service of copy of the above Motion was done by registered mail inasmuch as personal service
thereof is not practicable on account of lack of personnel.
LEILANI T. L. VILLARINO