UNIT 7

JURISDICTION OF ARBITRAL TRIBUNAL

Learning activity:

1. Create written objection on the grounds 1, 2 and 3 jurisdiction of arbitration tribunal.

Cite decided cases, articles, sections in your pleadings/ objections.

Form 1

Republic of the Philippines

SUPREME COURT
9TH Judicial Region
REGIONAL TRIAL COURT
Zamboanga Sibugay

Leere C. Bravo,
Plaintiff,

CIVIL CASE NO. 02182

For: COLLECTION OF SUM OF MONEY
JOEL BRAVO
Defendant.

MOTION FOR JUDMENT ON THE PLEADINGS

Plaintiff thru to this Honorable Court, most respectfully states that:

1. On June 5, 2021, Plaintiff filed the above-entitled case against Defendant with the
Honorable Court, paying the appropriate docket fess.

2. Summons and a copy of the complaint was finally served unto the defendant on June 30,
2021, thru defendant’s daughter, Carmina Deaf, a person of suitable age and discretion.
(Pls. see attached Summons and Sheriff’s Return of Sumons, Annexes “A and “B”,
respectively).

3. On July 28, 2021, Plaintiff’s counsel inquired with the office of this Honorable Court as to
whether or not defendant have already filed his Answer within the period prescribed by
Rules. Plaintiff’s counsel was then told by the person in-charge of civil cases that there is
yet no Answer filed.
4. The reglementary period to answer has expired without the defendant filing any answer.

5. For this reason, a judgment may be now be rendered by this Honorable Court motu proprio
or upon motion of the Plaintiff, as may be warranted by the facts alleged in the Complaint
and limited to what is prayed for therein.

WHEREFORE, premises considered, it is respectfully prayed for that judgment be

rendered in favor of Plaintiff and against the Defendant, ordering the Defendant to pay
Plaintiff:

a. The amount of Three Hundred Thousand Pesos (3000,000.00) representing

defendant’s indebtedness with legal interest from the date of final demand.
b. The amount of Fifty Thousand Pesos (50,000.00) as Attorney’s Fess plus
Appearance Fee at the rate of Ten Thousand Pesos (10,000.00) per court hearing:
c. The cost of suit.
Other reliefs just and equitable under the premises are also prayed for.

RESPECTFULLY SUBMITTED.

Cebu City, Philippines

ATTY. JOSEPH P. RUIZ

Counsel for the Plaintiff
MCLE No. 2546:
PTR No. 12544:
Cebu City
IBP No. 31131:
Cebu City
Email: Josephpardoruiz7@gmail.com
Contact No. 0955-448-3493