REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
CITY OF MAKATI, Branch 15

LENLEN CARS, INC.,

Plaintiff,

Civil Case No. 1037

- versus - For: Collection of Sum of Money

YORADYL MORALES,
Defendant.
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MOTION FOR JUDGMENT ON THE PLEADINGS

Plaintiff LENLEN CARS, INC., by counsel, and unto this Honorable Court,

respectfully moves that judgment on the pleadings be rendered in its favor and in support

thereof, respectfully states that:

1. On 20 September 2007, plaintiff initiated the instant case against the

defendant for collection of sum of money in the amount of One Million and Five Hundred

Thousand Pesos (P1,500,000,000.00).

2. On 2 October 2007, defendant submitted its Answer, where it admitted the

monetary obligation representing the amount of the 2005 Ford Expedition that was

delivered to plaintiff to defendant as previously ordered in the amount of One Million and

Five Hundred Thousand Pesos (P1,500,000.00).

3. Said Answer admits the material allegations of the Complaint and has not

tendered an issue; consequently, a judgment on the pleadings is proper.

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 4. This motion is not interposed for delay but solely for the foregoing

meritorious reasons.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that judgment on

the pleadings be rendered in favor of the plaintiff.

Other reliefs, as may be just and equitable, are likewise prayed for.

Makati City for Makati City: 13 October 2007.

PAÑO AND ASSOCIATES

Counsel for Plaintiff
LENLEN CARS, INC.
143 Kadiliman St.
KABLAG Tower
Makati City

By:
MARIA CHRISTINA E. GAVIOLA
PTR No. ___________
Roll No. ______

NOTICE AND REQUEST FOR HEARING

The Branch Clerk of Court

Regional Trial Court
City of Makati, Branch XV

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 Kindly submit the foregoing Motion for Judgment on the Pleadings for the
consideration and approval of the Honorable Court immediately upon receipt hereof and
kindly schedule the same for hearing on 15 December 2007 at 9:30 in the morning.

ANGELA ETHEL PAÑO

Atty. Chorizo Diaz

Counsel for Defendant
1130 Valencia Tower
Salcedo Village
Makati City

Please take notice that the foregoing Motion for Judgment on the Pleadings is
requested to be heard on 15 December 2007 at 9:30 in the morning.

ANGELA ETHEL PAÑO

Copy furnished:

Atty. Chorizo Diaz

Counsel for Defendant
1130 Valencia Tower
Salcedo Village
Makati City

EXPLANATION
(Pursuant to Rule 13, Sec. 11 of
the 1997 Rules of Civil Procedure)

The foregoing Motion for Judgment on the Pleadings is served upon the adverse
party’s counsel by registered mail due to distance constraints and the present lack of
manpower to personally serve the same.