Motion for Judgment on the Pleadings Sample

Republic of the Philippines

National Capital Judicial Region
 REGIONAL TRIAL COURT
Branch LXII (62)
Makati City

CARL HERNANDEZ,
                                            Plaintiff,

                    - versus -                                                               Civil Case No.111222

ROCK RAMOS,
                                       Defendant.
x-------------------------------------------x

MOTION FOR JUDGMENT ON THE PLEADINGS

          Plaintiff, by counsel, respectfully alleges that:

1.    On May 5, 2020, plaintiff sued defendant for a sum of money in the amount of
Four Hundred Thousand Pesos (P400,000.00) in relation to a loan;

2.    In his Answer, defendant admitted the obligation to pay the sum of money in the
loan and merely stated that he was asking to be given an extension of time to
pay his obligation but that plaintiff instead filed the Complaint; 

3.    Said Answer has not tendered any issue and in fact it can be read therefrom
that defendant admitted the obligation; consequently, a judgment on the
pleadings may be rendered. 

         WHEREFORE, it is respectfully prayed that this Honorable Court render

a judgment on the pleadings.

  
  Makati City, Philippines. November 11, 2020.

                                                                                    ATTY. OJ VILLONCO
                                                                                       Counsel for Plaintiff
Copy furnished through registered mail:

Atty. Walden Loja

Counsel for the Defendant
2 The Firm
Laguna Street, Quezon City
Registry Receipt No. ________
Post Office ________________
Date _____________________

The foregoing motion for judgement on the pleadings and its attachment were
served on Atty. Walden Loja by registered mail instead of personal service as
counsel for petitioner only has one messenger and personal service would have
resulted in the motion not being filed on time to the detriment of petitioner.

(Sgd.) Atty. OJ Villonco

Republic of the Philippines )
City of Makati ) s.s.

AFFIDAVIT

I, Carlo Vivit, a messenger of Atty. OJ Villonco, with office address at

__________________, after being duly sworn, deposes and states:

That on November 24, 2020, I served a copy of the following pleadings/papers by

registered mail in accordance with Section 10, Rule 13 of the Rules of Court:

Nature of Pleading/Paper:
Motion for Judgement on the Pleadings

in Case No. 111222 entitled Ramos vs Hernandez by depositing a copy in the post
office in a sealed envelope, plainly addressed to (Atty. Walden Loja) at 2 The Firm
Laguna Street, Quezon City with postage fully paid, as evidenced by Registry
Receipt No. 1982749 attached and with instructions to the post master to return the
mail to sender after ten (10) days if undelivered.

TO THE TRUTH OF THE FOREGOING, I have signed this Affidavit on November

24, 2020, in the City of Manila, Philippines.

(Sgd.) Carlo Vivit

Affiant
Republic of the Philippines )
City of Makati ) s.s.
SUBSCRIBED AND SWORN to before me this 24th day of November 2020 in
[Makati City], affiant exhibiting to me a competent evidence of his identity bearing his
photograph and signature, i.e., Philippine Passport issued on April 13, 2018 at DFA
Manila, which bears his photograph and signature.
NOTARY PUBLIC
Doc. No. ____
Book No.____
Page No. ____ Series of 2020.

K. Place, date, signature, address, Roll number, IBP receipt number, PTR
number
(oj pls check this)
City of Makati, 24 November 2020.

Atty. Walden Loja

Counsel for the Defendant
2 The Firm, Laguna Street,
Quezon City, Metro Manila
Roll No.
IBP OR No., date and place of issue
PTR OR No., date and place of issue

ADD NOTICE OF HEARING