REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch 61, Makati

ABCD BANK,

- versus -
CIVIL CASE NO. 199883
ELIZA SOBERANO,
Defendant.
x - - - - - - - - - - - - - - -x

MOTION FOR RECONSIDERATION

(to Set Aside Order of Default and
to Admit Attached Answer)

DEFENDANT, assisted by the Public Attorney's Office through the

undersigned counsel, most respectfully states that:

1. Defendant was declared to be in default on April 11, 2014 when she failed
to file her answer within the reglementary period. Herein attached as
Annex "1" is the said Order.

2. Defendant begs for a reconsideration of the said Order for the reason that
she did not receive a copy of the complaint nor any summons from this
Honorable Court regarding the above cited case. She only received on
April 23, 2014 a copy of the Order dated April 11, 2014, already declaring
her in default. She immediately sought assistance from the Public
Attorney's Office to avail of any remedies.

3. In the interest of substantial justice and for the reason earlier stated,
defendant begs the compassion of this Honorable Court to admit her
attached Answer. Delay in the proceedings of this case was never
intended.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Court to set aside the Order of default and to admit the
attached Answer.

Other just and equitable remedies are likewise prayed for.

Makati, April 30, 2015.

Respectfully submitted.

PUBLIC ATTORNEY'S OFFICE - Makati District Office

16th Floor Makati City Hall Building,
 Makati City

By:

ATTY. ENRICO GIL

Roll No. 12345, IBP No. 123456; 01.07.14;QC
MCLE Compliance No. IV 111445522; 03.28.12

NOTICE OF HEARING

Clerk of Court
METC Branch 61, Makati City

Atty. Katheryn Bernardo

Counsel for Plaintiff
1234 Teresa Street, Makati City

Greetings:

Please submit the foregoing for the consideration and approval of this
Honorable Court at the soonest possible time or on May 17, 2015 at 8:30
in the morning.

(Sgd.) ATTY. ENRICO GIL