Motion for Judgment on the Pleadings Sample

Republic of the Philippines

National Capital Judicial Region
METROPOLITAN TRIAL COURT
Branch LXII (62)
Makati City

STERLING BANK OF ASIA,

Plaintiff,

- versus - Civil Case No.111222

ELLA CORPUZ MAPA,

Defendant.
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MOTION FOR JUDGMENT ON THE PLEADINGS

Plaintiff, by counsel, respectfully alleges that:

1. On May 5, 2013, plaintiff sued defendant for a sum of money in the amount of Two Hundred
Thousand Pesos (P200,000.00);

2. In his Answer, defendant admitted the obligation and merely stated that he was asking to be
given an extension of time to pay his obligation but that plaintiff instead filed the Complaint;

3. Said Answer has not tendered any issue and in fact it can be read therefrom that defendant
admitted the obligation; consequently, a judgment on the pleadings may be rendered.

WHEREFORE, it is respectfully prayed that this Honorable Court render a judgment on

the pleadings.

Makati City, Philippines. August 5, 2013.

ATTY. VX YZ
Counsel for Plaintiff
 NOTICE OF HEARING

THE BRANCH CLERK OF COURT

MeTC - Branch 62
Makati City

ATTY. AB CD
Counsel for the Defendant
1234 Zamora Street, Pasay City

Greetings!

Please take notice that the undersigned counsel will submit the foregoing Motion to the
Honorable Court on August 27, 2013 at 8:30 in the morning for its favorable consideration and
approval.

VX YZ

Copy furnished by registered mail:

ATTY. AB CD
Counsel for the Defendant
2233 Zamora Street, Pasay City

EXPLANATION

Due to lack of messengerial services to effect personal service, a copy of the foregoing motion
was sent to defendant's counsel through registered mail.

VX YZ