Republic of the Philippines

FIFTH JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 19
Naga City

JUAN TAMAD
Plaintiff,
Civil Case No.:1234
- versus - For: Recovery of Possession with
Damages

MARIA MAKILING
Defendant.
X-------------------------------------------X

MOTION FOR LEAVE OF COURT

FOR THE EXTRATERRITORIAL SERVICE OF SUMMONS

COMES NOW, the plaintiff, through the undersigned counsel and

unto this Honorable Court, most respectfully avers:

1. That defendant is a resident of Tokyo, Japan with no

address in the Philippines while the property subject of the action is
located in the Philippines;

2. That, based on the foregoing, extraterritorial service of

summons is proper and available under Section 15, Rule 14 of the
Rules of Court.

WHEREFORE, Plaintiff respectfully prays that he be granted

leave of court for the extraterritorial service of summons on the
defendant, through personal service or by any other means that the
court may deem sufficient.

Such other relief and remedies as may be deemed just and

equitable under the premises are likewise prayed for.

City of Naga, 17 July 2011.

ISRAEL SOGUILON
Counsel for Defendant
20 TH Floor SBC Plaza, Naga City
By: Roll of Attorneys No. 12345
PTR No. 1234567; 01-05-2010; Naga City
IBP No. 234567; 01-05-2010; Naga City

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 REQUEST FOR AND NOTICE OF HEARING

Greetings: Please take notice that the foregoing Motion will be

submitted for the Court’s consideration and resolution on 18 July 2011
at 8:30 a.m. or as soon thereafter as matter and counsel may be heard.

COPY FURNISHED:

THE BRANCH CLERK OF COURT

Regional Trial Court Fifth Judicial Region
Naga City, Branch 19

MARIA PAGE
Counsel for Plaintiff
Ramaida Centrum
Naga City

ISRAEL SOGUILON
Counsel for Defendant
20 TH Floor SBC Plaza, Naga City
By: Roll of Attorneys No. 12345
PTR No. 1234567; 01-05-2010; Naga City
IBP No. 234567; 01-05-2010; Naga City

PROOF OF SERVICE

Copy furnished through personal service:

MARIA PAGE
Counsel for Plaintiff
Ramaida Centrum
Naga City

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REPUBLIC OF THE PHILIPPINES )
CITY OF NAGA………..………………)S.S.
X----------------------------------------------------X

AFFIDAVIT

I, JUAN DELA CRUZ, of legal age, married and a resident of

Naga City, after duly being sworn to in accordance with law hereby
state that:

1. I am the messenger of Israel Soguilon, counsel for defendant,

with office address at Barlin Street, Naga City, counsel on record in the
case entitled Recovery of Possession with Damages, Civil Case No.
1234, and as such messenger, I served upon the counsel of adverse
party the petition in said case as follows:

Maria Page, Coundel for Plaintiff, by personal service by

delivering personally copy of said motion upon said lawyer, who
acknowledged receipt thereof as shown by her signature on said
pleading, this 18th day of July 2011.

To the truth of the foregoing,I have signed this Affidavit on July

18, 2011 in the City of Naga, Philippines.

JUAN DELA CRUZ

Affiant

SUBSCRIBED AND SWORN to before me, a notary public in and

for Naga City, this 18th day of July 2011 at Naga City, Philippines.

ATTY. GIDIONNE M. SALVA

Notary Public

Doc. No. ;
Page No. ;
Book No. ;
Series of 2011.