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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.
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
Pasay City
Complaint
Mr. A
(Plaintiff)
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:
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.
3. other reliefs and remedies deemed just and equitable by this Honorable court.
(sgd)
Counsel X
IBP n0.____
MCLE no.____
PTR no.___
degalla09@gmail.com
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
IBP n0.____
MCLE no.____
PTR no.___
Doc.:__
Page no..___
National Capital Judicial Region
Pasay City
Mr. A
(Plaintiff)
Mr. B
(Defendant)
X----------X
Pasay City
Mr. A
(Plaintiff)
(Defendant)
X----------X
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.
4. there is a pending petition for certiorari in the denial of judgement on pleading filed by the
plaintiff.
Prayer:
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.
(sgd)
Mr. B
(plaintiff)
Notice of Hearing:
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
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
IBP no:____
MCLE N0.____
PTR no____
Degalla09@gmail.com
09176310630
Quezon City
Ms. B
vs.
Mr. A
(Defendant)
x----------x
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:
(sgd)
Ms. A
Plaintiff
Notice of Hearing:
Clerk of Court
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
Caloocan City
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
Caloocan City
IBP no.____
MCLE no:____
PTR No._____
email: degalla09@gmail.com