Republic of the Philippines

REGIONAL TRIAL COURT OF ILOCOS SUR

First Judicial Region
Branch 21 – Vigan City

JUAN TAMAD
Plaintiff, CIVIL CASE NO. 1018
FOR: SUM OF MONEY
-versus-

JUAN SIPAG
Defendant.
x-------------------------------------x

MOTION TO DECLARE DEFENDANT IN DEFAULT

PLAINTIFF, by the undersigned counsel, respectfully alleges that:

1. Plaintiff filed this complaint against defendant on January 1, 2021, summons were
served on defendant on January 15, 2021, as indicated by the Sheriff’sreturn, attached as
“ANNEX A”.

2. Defendant’s reglementary period to file answer ended on January 30, 2021 that no
motion for extension of such period was filed nor was any granted.

3. Plaintiff is entitled to a declaration of default and the right to present evidence ex parte
against defendant, after defendant’s failure to answer the Complaint against him, despite
the lapse of the time.

WHEREFORE, Plaintiff respectfully prays that Defendant be declared in default and that
Plaintiff be allowed to present evidence ex parte.

January 31, 2021, Vigan City, Ilocos Sur, Philippines.

(Sgd.)

(Sgd.)
PHREXILYN PAJRILLO
Counsel for the Plaintiff
Balaleng, Bantay, Ilocos Sur
Roll of Attorney No. 12345
IBP No. 12345/2-5-21
PTR No. 87654/12-22-20
MCLE Compliance No.: _____
Email Add: phrexilynpajarillo@gmail.com
C.P. No.: 09173456789

NOTICE OF HEARING

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Copy furnished thru Personal Service:
ABC
Counsel for the Defendant
Brgy 1, Vigan City (2700), Ilocos Sur

PROOF OF SERVICE

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