Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
City of Manila
BRANCH 05

MACARIO SAKAY,
Plaintiffs,
Civil Case No. 222222
-versus- For: collection of a sum of money

DIEGO SILANG
Defendant.
X-----------------------------------X

MOTION TO DECLARE DEFENDANT IN DEFAULT

PLAINTIFFS, thru the undersigned counsel, unto this

Honorable Court, most respectfully state that:

1. On May 11, 2023 the Complaint in this case was filed,

through counsel, by the Plaintiffs;

2. On June 02, 2023 summons together with the copy of the

complaint was served upon defendant per the Return of
Service of the same date;

3. However, no responsive pleading has been filed by the

defendant within the reglementary period;

4. Considering the failure of the defendant to file an Answer,

pursuant to Sec. 3, Rule 9 of the Rules of Court, defendant
should be declared in default;

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed unto this Honorable Court to Declare Defendant in
Default and to allow the plaintiff to present evidence ex-parte. Other
relief and remedies as may be deemed just and equitable under the
premises are likewise prayed for.

Malate, City of Manila, Philippines. June 06, 2023.

 HULTON GO
Counsel for the Defendants
IBP No. 1234, City of Manila
PTR No. 8888, May 2023
Roll of Attorneys No. 5555
MCLE Compliance No. 5544332211
124 Manila, Metro Manila

EXPLANATION

Copy of this motion was sent to the respondents by registered

mail with return card due to distance involved and lack of personnel
who will effect personal service.

NOTICE OF HEARING

The Clerk of Court

Regional Trial Court
Branch 05, City of Manila

Diego Silang.

Greetings!

Please take notice that the undersigned counsel submitted the

foregoing for the consideration of this Honorable Court on July 06,
2023 without prejudice to further appearance and oral arguments
which may be required by the court of the undersigned counsel.

HULTON GO
Copy furnished:

Diego Silang.
Defendant
2457 Malate, Metro Manila