Republic of the Philippines

Second Judicial Region

REGIONAL TRIAL COURT
Branch 31
Cabarroguis, Quirino
-oOo-

EDOLFO A. ALCANTARA
Petitioner,
-versus- SP Case No: 2018-09

EMELYN B. AGUSTIN, For: Custody of Minor Sophia

Respondent. Marie Alcantara
x----------------------------------------x

MOTION TO ORDER DEFAULT

Plaintiff, by counsel and unto this Honorable Court, respectfully states

THAT:

1. The records of the Honorable Court show that respondent was served
with copy of the summons and of the complaint, together with
annexes thereto on June 06, 2018;

2. Records show that counsel; for respondent filed a motion for

extension of 15 days within which to file answer or until July 7, 2018;

3. Upon verification however, the records show that Respondent

EMILYN B. AGUSTIN has failed to file her Answer within the
reglementary period specified by the Rules of Court despite the,
Extension to file Answer, Service of the summons and the Complaint;

4. As such, it is respectfully prayed that Respondent EMILYN B.

AGUSTIN 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 Respondent EMILYN B.

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

Other relief just and equitable are likewise prayed for.

25 September 2018, Diffun, Quirino.

MA. KAREN BALDONADO-GUILLERMO

Counsel for the Petitioner
Andres Bonifacio, Diffun, Quirino

COPY FURNISHED:
JOELETT L. BIBANGCO
Public Attorney II
Public Attorney’s Office
Hall of Justice
Brgy. Zamora, Cabarroguis, Quirino