REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

City of Malolos, Bulacan

Maria M. Dela Cruz

Plaintiff,
Civil case No. 20-10
-vs-
Civil Case for: Rescission
of Contract to Sell with
Joseph L. San Pedro and Martha S. San Pedro Damages
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 was served
with copy of the summons and of the complaint, together with annexes
thereto on March 8, 2020;

2.Upon verification however, the records show that Defendant Joseph

L. San Pedro and Martha S. San Pedro 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 Joseph L. San

Pedro and Martha S. San Pedro 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.

City of Malolos, Bulacan, Philippines, 24th Day of March 2020

 Atty. Christian Joseph E. Garcia
Counsel for the Plaintiff
PTR No. 22332
Attorneys Roll No. 70202
IBP membership no. 509
MCLE Compliance: 1022/ December 2021
Mater Dei Building
Poblacion, Malolos, Bulacan

COPY FURNISHED:
Atty. Christian James Guilalas
Atty. Mhelrose Grande