REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

BIAN CITY LAGUNA
BRANCH _____
EDISON ALBA,
Plaintiff
-versus-

Civil Case No. __________

For: Ejectment and Damages

ALLISON MERCADO
Defendant
x-----------------------------------------x
MOTION TO SET THE CASE FOR
PRELIMINARY CONFERENCE
Plaintiff Edison Alba (hereinafter, The Plaintiff), by counsel, unto this Honorable
Court, respectfully states that:

1 On April 30, 2014, Plaintiff received the copy of the Answer of the
Defendant Mercado in this case;

2 Considering that a Reply to the said Answer is no longer necessary due to

the fact that said Answer does not raise any new or substantial issue, or
raise issues which should more properly be addressed during the trial
proper, the said Answer is therefore the last pleading contemplated by the
Rules of Court;

As such, Plaintiff through undersigned counsel respectfully requests that

the instant case be immediately set for Preliminary Conference in
accordance with the rules of Court so as to:

a). consider the possibility of an amicable settlement;

b). define, simplify and clarify the issues for determination;
c). formulate stipulations of facts and admissions of documentary exhibits & limit the
number of witnesses to be presented; and

d) take up such other matters which may aid the court in the prompt disposition of the
case.
4. Considering the foregoing, Plaintiff by counsel respectfully moves that this
Honorable Court set the Preliminary Conference of the instant action.

RELIEF
WHEREFORE, premises considered, Plaintiff by counsel respectfully moves that
this Honorable Court:
(a) Set the Preliminary Conference of the instant case.
Other reliefs, just and equitable under the premises, are likewise prayed for.
Dasmarias City, Cavite to Bian City, Laguna , April 30, 2014.

VERIFICATION

I, EDISON ALBA, of legal age with address at Bian City, after having been
sworn to in accordance with law, hereby depose and state that:

I am the plaintiff in the above-captioned case.

I have caused, the preparation and filing of the foregoing Motion

I have read and understood the contents of the foregoing Motion and the
allegations therein and I attest that the same are true and correct of my
own personal knowledge and on the basis of the records in my
possession.

I likewise certify that the documents attached to this Motion are authentic
and duly executed.

EDISON ALBA
Affiant

SUBSCRIBED AND SWORN to before me, this ________ day of ____________

Bian City, affiant exhibited to me his Community Certificate No. 14174500 issued on
April 30, 2014 at Bian, Laguna.

Doc. No. _____;

NOTARY PUBLIC

Page No._____;

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Book No. ____;

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Series of 2014.

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Notice and copy furnished:

Atty. Ma. Regina N. Rendal

Counsel of Defendant (Ms. Allison Mercado)
Dasmarias City, Cavite

Greetings:
Please be informed that the instant Motion shall be submitted for the
consideration and approval of this Honorable Court immediately upon receipt hereof.
Ma. Regina N. Rendal
NOTICE
The Branch Clerk of Court
Metropolitan Trial Court, Branch 24
Bian City, Laguna
Kindly submit the foregoing motion for the consideration and approval of this
Honorable Court immediately upon receipt hereof.
Ma. Regina N. Rendal

EXPLANATION

A copy of this pleading was served to the other party by registered mail on
account of distance of the parties and lack of messengers to effect personal service.
Proof by registered mail is hereto attached.

This explanation is being made in compliance with the requirement of Section 11,
Rule 13 of the 1997 Rules of Civil Procedure.

Ma. Regina N. Rendal

REPUBLIC OF THE PHILIPPINES

DASMARINAS CITY

)S.S

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

AFFIDAVIT OF SERVICE

The undersigned, with address at Dasmarias, Cavite hereby states under oath
that:

1 Affiant served today the pleading below:

Pleading:

Motion to Set the Case for Preliminary Conference

Case Title:

Edison alba vs. Allison Mercado

Case No:

____________

Venue:

Metropolitan Trial, Branch _____, Binan City , Laguna

2 The pleading described above was served registered mail to:

Name & Address

Registry Receipt No.

Ma. Regina N. Rendal

Counsel of the Defendant ( Allison
Mercado)
Cabuyao Sta. Rosa Laguna

3 The registry receipt issued by the mailing office is attached to the original
pleading on file with the Court.

The registry return cards will be filed

immediately with the Court upon its receipt by the affiant.

___________________, Dasmarinas City.

MA. REGINA N. RENDAL

Affiant's Name and Signature

SUBSCRIBED AND SWORN TO before me this _____ day of _____________,

affiant exhibiting to me his Driver's License Number N0198226672 issued at Land
Transportation Office, Dasmarinas City on October 3, 2015.

Doc. No._______;

NOTARY PUBLIC

Page No._______;

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Book No. ______;

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Series of 2014.

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