REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL OURT

National Capital Judicial Region
Manila City

Linda Manalo
Plaintiff,

-versus- Case No._______

For: Unlawful Detainer

Anne Tan
Defendant

x-----------------------------x

MOTION TO DECLARE DEFENDANT IN DEFAULT

PLAINTIFF LINDA MANALO, by counsel, and unto this Honorable

Court, most respectfully aver that:

1. On 18 November 2021, the Honorable court sent a copy of the

service of summons and the complaint to the defendant at her
residence in 789 Bambang St, Tondo, Manila.

2. Upon verifying the Court records, it was discovered that Defendant

Tan failed to file her Answer within the reglementary period of thirty
(30) calendar days after service of summons.

3. Defendant is in default for failing to file the responsive pleading even

after she was served with the copy of summons and complaint.

PRAYER

WHEREFORE, the plaintiff respectfully prays that defendant Anne

Tan be declared in default pursuant to the Rule of Court.

Other reliefs which are just and equitable under the given
circumstance, are likewise prayed for.

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 19 December 2021, Manila City, Philippines.

ATTY. ISABEL SISON

Counsel for Plaintiff
Sison & Cruz Law Firm
958 A.H. Lacson St., Sampaloc, Manila
Roll No. 12345
IBP No. 123456, May 5, 2017
PTR No. xxxx 06-01-2017, Manila City
MCLE Compliance No. xxxx 06-01-2017
Phone No. 09391234567
E-mail: Isison@gmail.com

NOTICE OF HEARING

HON. CLERK OF COURT

Greetings,

Kindly, the motion be brought to the attention of the Honorable Court

immediately upon receipt thereof and set the same for hearing on the 27 th of
December 2021, 8:30 am.

ATTY. ISABEL SISON

Counsel for Plaintiff
Sison & Cruz Law Firm
958 A.H. Lacson St., Sampaloc, Manila
Roll No. 12345
IBP No. 123456, May 5, 2017
PTR No. xxxx 06-01-2017, Manila City
MCLE Compliance No. xxxx 06-01-2017
Phone No. 09391234567
E-mail: Isison@gmail.com

Page 2 of 3
Copy Furnished:

ATTY. YSABELLA CRUZ

Counsel for Defendant
765 Espana, Sampaloc, Manila
Roll No. 10945
IBP No. 789956, May 10, 2015
PTR No. xxxx 06-01-2015, Manila City
MCLE Compliance No. xxxx 06-01-2015
Phone No. 09367734567
E-mail: ysacruz@gmail.com

EXPLANATION

A copy if the Motion to declare defendant in default was served to

defendant Anne Tan through personal service.

Atty. Isabel Sison

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