REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

11th JUDICIAL REGION
Davao City
Branch 6

ANTONIO A. DELA CRUZ, JR.,

Plaintiff,

-versus- CIVIL CASE NO. _________

FOR: Collection of sum of money
with Damages
FRANCISCO Q. APOLINARIO,
Defendant.
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MOTION TO DECLARE DEFENDANT IN DEFAULT

PLAINTIFF, by counsel and unto this Honorable Court,

respectfully states

1. The records of the Honorable Court show that Defendant

was served with copy of the summons and of the complaint, together
with annexes thereto on 15 February 2020;

2. Upon verification however, the records show that

Defendant has failed to file his Answer within the reglementary
period specified by the Rules of Court despite the service of the
summons and the complaint;

3. As such, it is respectfully prayed that Defendant be

declared in default pursuant to the Rules of Court and that the
Honorable Court proceed to render judgment as the complaint may
warrant.

PRAYER

WHEREFORE, it is respectfully prayed that Defendant

FRANCISCO Q. APOLINARIO be declared in default pursuant to the
Rules of Court and that the Honorable Court proceed to render
judgment as the complaint may warrant.

Other reliefs, just and equitable under the given circumstances,

are likewise prayed for.

RESPECTFULLY SUBMITTED.
 March 13, 2020, Davao City, Philippines.

SANTOALLA and Associates Law Offices

Counsel for the Petitioner
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City
Tel. Nos.: (082) 282-3662
thesantoalla@associateslaw.com

By:

ATTY. STEPHANIE M. SANTOALLA

IBP NO. 071717, 12/12/19, Davao City
PTR NO. 071717, 12/12/19, Davao City
ROLL ATTORNEY NO. 11077
MCLE Comp. No. IV-0004785, 3/2/19
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City
Tel. Nos.: (082) 282-3662
smsantoalla@associateslaw.com

NOTICE OF HEARING

HON. CLERK OF COURT

11th Judicial Region
RTC, Branch 6

Greetings.

Kindly the foregoing motion to the attention of the Honorable

Court immediately upon receipt thereof and set the same for hearing
on 29 March 2020, 8:30 A.M.

ATTY. RAMIL W. CASTANEDA

Counsel for the defendants.
3/F, ABC Building, Damosa Complex
Lanang, Davao City
Please be notified that the foregoing motion will be set for hearing
this 20 February 2015, 8:30 A.M.

COPY FURNISHED: (Personal Service)

Sgd.
ATTY. RAMIL W. CASTANEDA
Counsel for the defendants.
3/F, ABC Building, Damosa Complex
Lanang, Davao City