a. Significant changes : 1. The rule on Motion to Dismiss was eliminated. 2.

Judicial Affidavits
of witness should be attached at the complaint. 3. notice of hearing is not necessary to non-
litigious motions. 4. Reply is now prohibited unless there is a rejoinder. 5. the use of electronic
mail as a recognized mode of service.

b. Certification againts forum shopping is necessary a part of an initiatory pleading, which

certifies that the plaintiff have not initiated or no knowledge that a same action with the parties
parties were filed to any courts or tribunals. Verification in necessary included in the complaint
and answer which states the plaintiff/defendant understands the contents of the pleading and that
they caused the preparation thereof, attest to the truthfulness and correctness of the allegations
stated therein and based on personal knowledge of the person executing the pleading.

c. A member of the Bar having applied for the court who has jurisdiction for notary public

d. Judicial Affidavit - is a statement of the witness under oath that supports the claim or defense
of the respective parties.

e. Civil actions are those actions that actions which seeks to enforce the rights of a party as
againts the other based on the case of action.
Republic of the Philippines

National Capital Judicial Region

Metropolitan Trial Court, Branch __

Pasay City

Complaint

Mr. A

(Plaintiff)

vs. Docket no.___

For: Collection of Sum of Money

Mr. B

(Defendant)

X----------X

1. Plaintiff is of legal age,Filipino and a resident of Purok 3, Menlo St., Zone 4, Pasay city,
where he may received notices from this court.

2. Defendant is of legal age, Filipno and a resident of block 2, Remedios St., Malate, Manila.

3. That on October 13, 2018, Mr. B borrowed from the Plaintiff an amount of two hundred fifty
thousand pesos (P250, 000) with an interest thereon of 5% monthly.

4. To secure the prompt and full payment of the principal and interest, defendants made and
executed on October 13, 2018 a Deed of Real Estate Mortgage in favor of plaintiff a parcel of
land with improvement situated at Baybay, Makato, Aklan containing an area of more or less
four hundred seventy-eight (478) square meters, declared under the name of Mr. B, with an
assessed value in the sum of ₱13,380.00, as per tax effectivity for the year 2018. Said land is
covered by OCT No. P-5561. (Attached is a copy of the mortgage agreement as Annex A)
5. As the obligation fell due, Mr. B failed and refused to pay both the principal obligation and the
interest due starting from November 15, 2018, to the present despite repeated demands. (attached
is a copy of the Demand letter for payment of loan dated November 17, 2018)

Prayer:

The plaintiff prays to this honorable court:

1. That the defendant pay the principal of the loaned amount of two hundred fifty thousand pesos
(P250, 000) and interest amounting to 5% on a monthly basis.

2. Payment of legal fees amounting to fifty thousand pesos (P50,000)

3. other reliefs and remedies deemed just and equitable by this Honorable court.

Pasay city, December 21, 2019

(sgd)

Counsel X

Counsel to the Plaintiff

Bldg 6, lot 4, Menlo St. Pasay city

Roll Of Atty no. ___

IBP n0.____

MCLE no.____

PTR no.___

degalla09@gmail.com

contact no. 09176310630

Verification and Certification Againts Forum Shopping

I, Mr. A, of legal age, a resident of Purok 3, Menlo St., Zone 4, Pasay city, after being sworn to
in accordance with law, do hereby depose and state that:
1. I, am the Plaintiff, in the Above entitled case, caused the formulation of this pleading.

2. That i read and understand the contents of this pleading, and state the truth and correctness of
the allegations stated herein based on my personal knowledge.

3. That i have not commenced any action with the same subject and same parties to any court or
Tribunal, and if ever i have to knowledge of such, i hereby inform this Honorable court of such
fact within 5 days.

In, view whereof, i hereunto affix may signature this 21st day of December, 2018 at Pasay City.

(sgd)

Mr. A

(Plaintiff)

subscribed to before me, this day of 21st day of December, 2018 at Pasay city, the affiant
presenting his driver's license with no. 1234135, expiring on April 17, 2017.

Counsel X

Bldg 6, lot 4, Menlo St. Pasay city

Roll Of Atty no. ___

IBP n0.____

MCLE no.____

PTR no.___

Doc.:__

Page no..___
National Capital Judicial Region

Metropolitan Trial Court, Branch __

Pasay City

Mr. A

(Plaintiff)

vs. Docket no.___

For: Collection of Sum of Money

Mr. B

(Defendant)

X----------X

ational Capital Judicial Region

Metropolitan Trial Court, Branch __

Pasay City

Mr. A

(Plaintiff)

vs. Docket no.___

For: Collection of Sum of Money

Mr. B

(Defendant)

X----------X

MOTION to Postpone Proceeding

Defendant as represented by Counsel, respectfully states that;

1. That the defendant filed his answer within the time allowed by court.

2. that the Court denied the motion for judgment on the pleadings for lack of merit dated August
23, 2020 , which was received by both parties August 30, 2020.

3. That the clerk of court has yet to schedule a pre-trial conference.

4. there is a pending petition for certiorari in the denial of judgement on pleading filed by the
plaintiff.

Prayer:

the defendant respectfully prays to this honorable court,

1. that the proceeding be postponed until the ongoing petition for certiorari has been resolved.

2. other reliefs and remedies, deemed just and equitable in this case.

manila, September 5, 2020

(sgd)

Mr. B

(plaintiff)

Notice of Hearing:

Counsel to the Plaintiff

Clerk of Court
Greetings, please be informed that the hearing on this motion shall be scheduled on September
10, 2020, 9:00 am.

(sgd)

Counsel Y

Counsel to the Defendant

Block3, sector 5, Malate, MAnila'

Roll of Atty no:__

IBP no:____

MCLE N0.____

PTR no____

Degalla09@gmail.com

09176310630

PROOF OF SERVICE

Service to the counsel of the plaintiff was effected by registered mail because of the lack of
manpower.

sgd)

Counsel Y

Counsel to the Defendant

Block3, sector 5, Malate, MAnila'

Roll of Atty no:__

IBP no:____

MCLE N0.____
PTR no____

Degalla09@gmail.com

09176310630

Republic of the Philippines

National Capital Judicial Region

Family Court Branch __

Quezon City

Ms. B

(Plaintiff) Docket no:

re: Petition for Declaration of Nullity of Marriage

vs.

Mr. A

(Defendant)
x----------x

Motion to Declare Defendant in Default

Plaintiff, as represented by counsel, respectfully states that;

1. that the Defendant personally received a summon for complaint for petition to declare nullity
of marriage last March 25, 2020 as manifested in the return of service of Sheriff _.

2.That after more 30 days from received thereof until this date, the defendant failed to file a
responsive pleading to this honorable court.

Prayer:

The plaintiff prays to this honorable court that;

1. To declare the defendant in default.

2. To allow the plaintiff to present evidence ex parte

3. other reliefs and remedies deemed just and equitable.

Caloocan City, June 2, 2020

(sgd)

Ms. A

Plaintiff

Notice of Hearing:

Clerk of Court

Family Court Branch __

Quezon city,

Greetings, i would like to inform that the hearing for this motion be held on June 8, 2020, Friday
at 9:00 am.
(sgd)

Frederick C. Egalla

counsel to the Plaintiff

Block 2, Bldg 3, Bagong Silang

Caloocan City

Roll of Attorney No. ___

IBP no.____

MCLE no:____

PTR No._____

email: degalla09@gmail.com

PROOF OF SERVICE

The service of this motion was served through registered mail because of lack of manpower.

(sgd)

Frederick C. Egalla

counsel to the Plaintiff

Block 2, Bldg 3, Bagong Silang

Caloocan City

Roll of Attorney No. ___

IBP no.____

MCLE no:____
PTR No._____

email: degalla09@gmail.com