REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH ___
CALOOCAN CITY
X
Petitioner,
-versus-

CIVIL CASE NO.

FOR:
Defendant,

X----------------------------------X
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 Y was served
with copy of the summons and of the complaint, together with annexes thereto on
15 November 2015 ;
2. Upon verification however, the records show that Defendant Y 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 Y be declared in default
pursuant to the Rules of Court and that the Honorable Court proceed to render
judgment as the complaint may warrant.
PRAYE R
WHEREFORE, it is respectfully prayed that Defendant Y 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 relief just and equitable under the given circumstances, are likewise
prayed for.
Caloocan City, Philippines, __Date__.
(COUNSEL)

NOTICE OF HEARING
HON. CLERK OF COURT
BR. ______
Greetings.

Kindly forward the foregoing motion to the attention of the Honorable Court
immediately upon receipt thereof and set the same for hearing on
____DATE____, TIME.

ATTY. XYZ
Counsel for the Defendant

Please be notified that the foregoing motion will be set for hearing this
____DATE_____, TIME.

COPY FURNISHED:
ATTY. XYZ
RECEIVED BY: