Kinds of Motions

Republic of the Philippines
REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
Branch 2, San Pablo City
People of the Philippines,

Plaintiff
Criminal Case No. 12345
-versus- For: Robbery
Alyanna Bautista,
Accused
x-------------------------------------------------x
MOTION TO WITHDRAW INFORMATION
Prosecution, respectfully alleges:
1. That after the preliminary investigation, prosecution resolved to file the present
case;
2. That after the information was file, private complainant executed an Affidavit of
Desistance stating that after careful evaluation of the case, he relies that the
complaint was filed out of misunderstanding;
3. Prosecution, by the execution of Affidavit of Desistance would not be able to prove
the guilt of the accused.
WHEREFORE, it is respectfully prayed that the information be withdrawn.
San Pablo City, February 6, 2020
(Sgd.) Fiscal Juan dela Cruz
NOTICE OF HEARING
Greetings:
Kindly set the foregoing motion on the 14th of February 2020 at 10:00 a.m. or any
date convenient to the court.
Copy furnished:
ATTY. JUANITA CRUZ

Counsel of (plaintiff or defendant)
Unit 1, Building X, Kian Seng Trading,
San Pablo City, Laguna
Service of Motion: (Explanation of service)
The adverse party was furnished with the hearing of motion personally evidenced by the
signature of the clerk who received it.
Proof of Service: Registered mail – registry receipt


Plaintiff
-versus- For: Robbery
Alyanna Bautista,
Accused
x-------------------------------------------------x
MOTION FOR LEAVE TO AMEND INFORMATION
Prosecution, respectfully moves:
1. For the amendment of information attached hereto;

2. That the amended information incorporated hereto is a matter of right.
WHEREFORE, it is respectfully prayed that the amended information be admitted in

order that the action may be determined completely that rights of the parties.
(Sgd.) Fiscal Juan dela Cruz
NOTICE OF HEARING
Greetings:
Kindly set the foregoing motion on the 14th of February 2020 at 10:00 a.m. or any
date convenient to the court.
Copy furnished:
ATTY. JUANITA CRUZ

The adverse party was furnished with the hearing of motion personally evidenced by the
signature of the clerk who received it.


Plaintiff
-versus- For: Reckless Imprudence
Resulting to Physical Injury
Alyanna Bautista,
Accused
x-------------------------------------------------x
MOTION FOR REINVESTIGATION
Accused respectfully moves:
1. That the case Reckless Imprudence Resulting to Physical Injury was filed against me is
pending at the Municipal Trial Court;
2. That the case was filed by the prosecution and the accused was not able to file the answer
during the preliminary investigation when the case was pending at the Public Prosecutor’s
Office;
3. That the accused is requesting for a reinvestigation before the public prosecutor in order
to submit his counter affidavit in order to determine the proper parties that may be charged
in this case;
4. That this motion is filed for the reason stated and not for the purpose of delaying the
proceedings of this case.
WHEREFORE, it is respectfully prayed that the motion for reinvestigation be granted.
Atty. Juan dela Cruz

Counsel for the accused
NOTICE OF HEARING
Greetings:
Kindly set the foregoing motion on the 14 th of February 2020 at 10:00 a.m. or any date
convenient to the court.
Copy furnished:
ATTY. JUANITA CRUZ

The adverse party was furnished with the hearing of motion personally evidenced by the signature
of the clerk who received it.

Arianna Bernabe,
Plaintiff
Civil Case No. 12345
-versus- For: Collection of Sum of Money
Xerex Yan,
Defendant
x-------------------------------------------------x
MOTION FOR EXTENSION OF TIME
Defendant, assisted by counsel respectfully states that:
1. That the defendant received summons on February 4, 2020.

2. That unfortunately, the defendant will not be able to file his answer on or before due date
because of the tremendous pressure on other equally urgent matter requiring preparation
of pleadings and daily trial appearances, and he needs an additional twenty (20) days to
file his answer or up to February 24, 2020.
3. That this motion is filed solely for the reason stated and not for the purpose of delaying
the proceedings of this case.
WHEREFORE, it is respectfully prayed that the motion be granted and that the defendant be
given an extension of twenty (20) days from February 4, 2020 to February 24, 2020.

Counsel for the Defendant
Unit 88, ABC Building,
XY Street, San Pablo City,
Laguna
NOTICE OF HEARING
Greetings:
Kindly set the foregoing motion on the 24th of February 2020 at 10:00 a.m. or any date
Copy furnished:
ATTY. JUANITA CRUZ

Counsel for the Plaintiff
The adverse party was furnished with the hearing of motion personally evidenced by the signature
of the clerk who received it.

Arianna Bernabe,
Plaintiff
Xerex Yan,
Defendant
x-------------------------------------------------x
MOTION FOR POSTPONEMENT
Plaintiff, assisted by counsel, respectfully moves that:
1. That the undersigned received an order from the RTC Judge setting the initial hearing on
February 14, 2020 at 10:00 a.m.
2. That unfortunately, counsel is already committed to appear at Calamba City previously to
the scheduled hearing in San Pablo City;
3. The undersigned counsel respectfully moves for the resetting of initial hearing due to
conflict of schedule;
4. That this motion is file for the reason stated and not for the purpose of delaying the
proceedings in this case.
WHEREFORE, is it respectfully prayed that the initial hearing set on February 14, 2020 be
reset on February 21, 2020 or to any day available to the court.

Laguna
NOTICE OF HEARING
Greetings:
Kindly set the foregoing motion on the 21st of February 2020 at 10:00 a.m. or any date
Copy furnished:
ATTY. JUANITA CRUZ

The adverse party was furnished with the hearing of motion personally evidenced by the signature of
the clerk who received it.

Arianna Bernabe,
Plaintiff
Xerex Yan,
Defendant
x-------------------------------------------------x
MOTION TO DECLARE DEFENDANT IN DEFAULT
Plaintiff assisted by counsel respectfully moves that:
1. That the defendant was served by summons on January 2, 2020;

2. That despite the lapse of the period to answer, the defendant failed to file his answer, thus
the defendant may be now declared in default.
WHEREFORE, it is respectfully prayed that the defendant be declared in default and that the
plaintiff be allowed to present his evidence ex parte and that the acceptance of evidence be
delegated to the Clerk of Court.

Laguna
NOTICE OF HEARING
Greetings:
Kindly set the foregoing motion on the 21st of February 2020 at 10:00 a.m. or any date
Copy furnished:
ATTY. JUANITA CRUZ


Arianna Bernabe,
Plaintiff
Xerex Yan,
Defendant
x-------------------------------------------------x
MOTION/ENTRY OF APPEARANCE
Sir:
Please enter the appearance of the undersigned counsel for the plaintiff in the above-
entitled case for all legal purposes.

Laguna
Copy furnished:
ATTY. JUANITA CRUZ

For criminal case
Sir:
Please enter the appearance of the undersigned counsel as private prosecutor for the
plaintiff (criminal case) in the above-entitled case under the direct control and supervision of the
public prosecutor for all legal purposes.
THE LAW FIRM OF
XAVIER, YUAN AND ZUNIGA
San Pablo City, Philippines
Tel No. (049) xxx xxxx/Mobile No. 0919 xxx xxxx
e-mail add: xyz@gmail.com
February 6, 2020
Mr. Alexander Broas,
We would like to inform you that you have an unpaid obligation to our client Xerex Yaun
in the amount of P88,888.88 evidenced by a promissory note.
We are giving you five (5) days to settle the said obligation or before February 11, 2020
or we will be constraint to file a case against you with the court of proper jurisdiction.
Yours very truly,

(Sgd.) Juan dela Cruz
XYZ Law Firm
San Pablo City

Kinds of Motions

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Republic of the Philippines

REGIONAL TRIAL COURT

People of the Philippines,

MOTION TO WITHDRAW INFORMATION

Prosecution, respectfully alleges:

WHEREFORE, it is respectfully prayed that the information be withdrawn.

San Pablo City, February 6, 2020

(Sgd.) Fiscal Juan dela Cruz

ATTY. JUANITA CRUZ

Service of Motion: (Explanation of service)

Proof of Service: Registered mail – registry receipt

People of the Philippines,

MOTION FOR LEAVE TO AMEND INFORMATION

Prosecution, respectfully moves:

1. For the amendment of information attached hereto;

WHEREFORE, it is respectfully prayed that the amended information be admitted in

San Pablo City, February 6, 2020

(Sgd.) Fiscal Juan dela Cruz

ATTY. JUANITA CRUZ

Service of Motion: (Explanation of service)

Proof of Service: Registered mail – registry receipt

People of the Philippines,

MOTION FOR REINVESTIGATION

Accused respectfully moves:

WHEREFORE, it is respectfully prayed that the motion for reinvestigation be granted.

San Pablo City, February 6, 2020

Atty. Juan dela Cruz

ATTY. JUANITA CRUZ

Service of Motion: (Explanation of service)

Proof of Service: Registered mail – registry receipt

MOTION FOR EXTENSION OF TIME

Defendant, assisted by counsel respectfully states that:

1. That the defendant received summons on February 4, 2020.

San Pablo City, February 6, 2020

Atty. Juan dela Cruz

ATTY. JUANITA CRUZ

Service of Motion: (Explanation of service)

Proof of Service: Registered mail – registry receipt

MOTION FOR POSTPONEMENT

Plaintiff, assisted by counsel, respectfully moves that:

San Pablo City, February 6, 2020

Atty. Juan dela Cruz

ATTY. JUANITA CRUZ

Service of Motion: (Explanation of service)

Proof of Service: Registered mail – registry receipt

MOTION TO DECLARE DEFENDANT IN DEFAULT

Plaintiff assisted by counsel respectfully moves that:

1. That the defendant was served by summons on January 2, 2020;

San Pablo City, February 6, 2020

Atty. Juan dela Cruz

ATTY. JUANITA CRUZ

Service of Motion: (Explanation of service)

Proof of Service: Registered mail – registry receipt

San Pablo City, February 6, 2020

Atty. Juan dela Cruz

ATTY. JUANITA CRUZ

Service of Motion: (Explanation of service)

Proof of Service: Registered mail – registry receipt

For criminal case

Mr. Alexander Broas,

Yours very truly,

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