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Republic of the Philippines

REGIONAL TRIAL COURT


Branch 9
th
10 Judicial Region
City of Malaybalay

BUKIDNON PLANTERS ASSOCIATION, CIVIL CASE NO. 5028-18


INC. REP. BY ANTHONY QUEJADA,
Plaintiff, For:

-versus-

GENARO DUROTAN, SUM OF MONEY W/


Defendant. DAMAGES
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MOTION TO DECLARE DEFENDANT IN DEFAULT

COMES NOW, Plaintiff, through the undersigned counsel


and unto this Honorable Court, most respectfully states, that:

1. The records of this case show that Defendant through


Ahlmei Buli-buli (defendant’s house helper), was served
with copy of the summons and of the complaint,
together with annexes thereto on August 14, 2018 per
Sheriff’s Return dated August 15, 2018 signed by Sheriff
IV Levy B. Akut, Jr;

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
upon him;
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


_____________ 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 are likewise prayed for.

Malaybalay City, Bukidnon. January 18, 2019.

LAGAMON AND ASSOCIATES LAW OFFICE


COUNSEL FOR PLAINTIFF
2nd Floor JAMSTAR Building, Corners JP Carillo- San Isidro Sts.,
Barangay 5, Malaybalay City, Bukidnon

By:

DENCE CRIS L. RONDON


Member of the Bar
PTR No. 8154304/03-JAN-2019
IBP No. 62183/04-JAN-2019
ROLL of Attorney’s No. 67495
TIN 496-556-017-000
MCLE Compliance No. VI-00011647

Copy furnished:

GENARO DUROTAN
Poblacion, Quezon
Bukidnon
NOTICE

THE CLERK OF COURT


RTC, Branch 9
Malaybalay City, Bukidnon

GENARO DUROTAN
Poblacion, Quezon
Bukidnon

Please take note/submit the foregoing motion for the


consideration and approval of the Honorable Court at a date and time
most convenient to the Honorable Court.

DENCE CRIS L. RONDON

EXPLANATION

(Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure)

Due to distance, time constraints, and sufficient manpower,


personal filing to Genaro Durotan was not resorted to and instead a
copy of the same was sent via registered mail with attached registry
receipts to the addressee.

DENCE CRIS L. RONDON