REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

THIRD JUDICIAL REGION
MALOLOS CITY, BULACAN
BRANCH 83

RAFAEL O. JOSE rep. by AIF,

ROMUALDO G. MENDOZA
Plaintiff,
Civil Case No. 14-M-2017
- versus -

SERGIO ELCARTE, et. al.,

Defendants.
x———————————————x

ENTRY OF APPEARANCE WITH MOTION TO DECLARE

DEFENDANT RICARDO ELY IN DEFAULT

Plaintiff, RAFAEL O. JOSE rep. by Attorney-in-Fact, ROMUALDO

G. MENDOZA, through counsel, unto this Honorable Court, most respectfully
states:

Entry of Appearance as
Collaborating Counsel.

1. Kindly enter the appearance of the undersigned counsel, VALMORES

MADROÑO AND ASSOCIATES, as collaborating counsel of Atty. Rolando V.
Zubiri of 1FG. Palm Tree Villas 2, Newport Blvd. Newport City, Villager Air
Base Pasay City, in the above-captioned case.

2. Accordingly, it is respectfully requested that copies of all court processes,

notices, orders, papers, documents and pleadings filed relative to the above-
captioned case be furnished and served upon the undersigned counsel at its
address indicated below.

Defendant Ricardo Ely failed

to file his Answer on the
Complaint within the
reglementary period.

3. Defendant Ricardo Ely received a copy of the Complaint and was served a
copy of Summons where Defendant Ricardo Ely was given by the Honorable
Court until 17 March 2017 within which to file his Answer on the Complaint.
4. However, it appears from the records that Defendant Ricardo Ely has not
submitted his Answer on the Complaint, nor did he file any motion or pleading
that could have interrupted the reglmentary period for filing an Answer.

5. As such, it is respectfully prayed that Defendant Ricardo Ely be declared

in default pursuant to Sec. 3 Rule 9 of the Rules of Court, and that the
Honorable Court issue an Order allowing Plaintiff to present evidence ex-parte
in support of its complaint against Defendant Ricardo Ely.

PRAYER

WHEREFORE, it is respectfully prayed that the foregoing entry of

appearance of be noted, and that the Honorable Court issue an Order: (1)
declaring Defendant Ricardo Ely in default; and (2) allowing Plaintiff to present
evidence ex-parte in support of its complaint and claims for damages against
Defendant Ricardo Ely.

Other reliefs just and equitable are likewise prayed for.

Respectfully submitted, Makati City for Malolos, Bulacan,

____________.

Valmores Madroño and Associates

Suite C3, 3rd Floor 2285 Green Sun Building
Chino Roces Extension, Makati City 1231, Philippines
Email Address : info@valmoresmadrono.com
Tel: +632 463 0550

By:

Carlos Celestino F. Romulo

IBP No. 1055395; 1/3/2017 PPLM Chapter
PTR No. 2426844; 01/11/17; Muntinlupa City
Attorney’s Roll No. 66513
MCLE Compliance No. : Exempted pursuant to
MCLE Governing Board Order No. 1s. 2008
Email: attycarlos@valmoresmadrono.com
 Rydely C. Valmores
IBP No. 1054157; 12/19/16 (for 2017) Misamis Oriental
PTR No. MKT 5909553; 01/3/17; Makati City
Attorney’s Roll No. 44731
MCLE Compliance No. V-0001888 valid until April 14, 2019
Email: attyrydely@valmoresmadrono.com

Lea Gay M. Josef

IBP No. 004335; 5/8/17 RSM Chapter
PTR No. 7037292; 7/31/17 Marikina City
Attorney’s Roll No. 68260
MCLE Compliance No: Exempted pursuant to
MCLE Governing Board Order No. 1s. 2008
Email: attylea@valmoresmadrono.com

NOTICE OF HEARING and COPY FURNISHED

Hon. Clerk of Court

Branch 83
Regional Trial Court
Malolos, Bulacan

ATTY. ROLANDO V. ZUBIRI

Co-Counsel for Plaintiff
1FG Palm Tree Villas 2
Newport Blvd., Newport City
Villamor Air Base
Pasay City

The Law Offices of Attorneys:

Atty. Matt Jayson S. Villanueva
Atty. Jose M. Cruz
Atty. Ralph Ernest M. Gopela
Counsel for Defendant NADJI MOLL
2nd Floor SRDC Bldg. (beside Robinson’s Place Malolos)
Mc Arthur Highway, Malls City, Bulacan

ATTY. MONALIZA B. IBARRA

Counsel for Defendant OLIVIA JUACALLA
Public Attorney’s Office
Department of Justice
Commercial Bldg. II
Capitol Compound, City of Malolos
HEIRS OF SERGIO ELCARTE
Defendants
Sitio Pastol, Brgy. Muzon
San Jose Del Monte, Bulacan

RICARDO ELY
Defendant
Sitio Pastol, Brgy. Muzon
San Jose Del Monte, Bulacan

Greetings:

Considering that there is no more issue on this motion to be resolved by

having a proceeding, as the fact of their default can be resolved by reference to
the court record, it is hereby requested that this motion be considered by the
Honorable Court without further oral argument.

CARLOS CELESTINO F. ROMULO

EXPLANATION

Due to distance and lack of messengers, this Entry of Appearance with

Motion to Declare Defendant Ricardo Ely in Default is being filed with the
Honorable Court, and served on the corresponding parties by private courier.

CARLOS CELESTINO F. ROMULO