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Republic of the Philippines

REGIONAL TRIAL COURT


Region VII Branch 8
Cebu City

JUAN ILOK

Defendant.

Plaintiff,

-versusCIVIL CASE NO. 4292324-L


For: Collection of a Sum
Money

BRAD ARMPIT

of

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

COMPLAINT

PLAINTIFF, thru the undersigned Counsel, unto this Honorable Court,


respectfully alleges:

1.

That Plaintiff is of legal age, Filipino, single and with residence at

Pardo, Cebu City.

2.

That Defendant is likewise of legal age, Filipino, single and with

residence at Pardo, Cebu City.

3.

That on March 7, 2007 the defendant borrowed the sum of money

in the amount of ONE HUNDRED FIFTY THOUSAND PESOS (PHP 150 000.00)
to be paid on July 31, 2007 in the presence of Pedro Siponon and Jose Kogmohon.

4.

That upon due date the defendant paid only the amount of ONE

HUNDRED THOUSAND PESOS (PHP 100 000.00).

5.

That upon demand of the remaining balance the defendant refuses

to pay the amount of FIFTY THOUSAND PESOS (PHP 50 000.00).

6.

That the complainant try to settle the dispute within the barangay

level. After further demand the defendant failed to comply his obligation.

7.

That by reason of defendants unjustified acts as well as bad faith

and intentional refusal to pay his overdue obligation, Plaintiff is entitled to the
award of moral damages in the amount of P10,000.00;

16.

That by reason of defendants violation and disregard of Plaintiffs

rights, the award of exemplary damages in the amount of P10,000.00 is likewise


warrant to serve as a deterrent to the commission by the defendant and to others
similarly-minded of similar acts in the future.

PRAYER
WHEREFORE, PREMISES CONSIDERED, it is most respectfully prayed
of this Honorable Court that, after due hearing, judgment be rendered against
the defendant ordering the latter to pay the plaintiff as follows:

1.

The amount of FIFTY THOUSAND PESOS representing the unpaid

balance due on July 31, 2007;


2.

The amount of P10,000.00 as and by way of moral damages;

3.

The amount of P10,000.00 as and by way of exemplary damages;

4.

Cost of suit.

Other reliefs just and equitable under the premises are likewise prayed for.

SUBSCRIBED AND SWORN to before me this ______ day of


January 2008 at Cebu City, Philippines.

I FURTHER CERTIFY that I have personally examined the affiantcomplainant and that I am satisfied that he voluntarily executed and understood his
Complaint-Affidavit.

Atty. HARVY SANORIA HALASAN


Counsel for the Plaintiff
Halasan Law Office Cebu City
Roll No. 76430 IBP No. 352980 dated 1-2-08
MCLE Compliance No. 11-00043527

VERIFICATION/CERTIFICATION
OF NON-FORUM SHOPPING
I, JUAN ILOK, Filipino, of legal age with address at Pardo Cebu City after
having been duly sworn on accordance with law depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That I caused the preparation of the foregoing Complaint and I have
read the allegations therein and certify that the same are true and correct of my
own personal knowledge;
3. That I further certify that I have not commenced any other action
involving the same issues before the Supreme Court, Court of Appeals or any
division thereof or any tribunal or agency; and to the best of my knowledge no
such action is pending before the Supreme Court, Court of Appeals or any
division thereof or any tribunal or agency;
4. That in the event that any action involving the same should be made
known, I hereby bind myself to report the same within five (5) days from
knowledge thereof to this Honorable Court.
WITNESS WHEREOF, I hereunto set my hand this _______ day of
________, ________ at Quezon City, Metro Manila, Philippines.

JUAN ILOK
Plaintif

SUBSCRIBED AND SWORN TO before me this ______ day of ______,


______ at Quezon City, affiant having exhibited to me her CTC No. ___________
issued on __________ at __________.

NOTARY PUBLIC
Doc. No._____
Page No. ____
Book No. _____
Series of _____

Republic of the Philippines


REGIONAL TRIAL COURT
National Capital Judicial Region
Branch ____, Quezon City

Defendant.

NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS

CIVIL CASE NO. _____


For: Collection of a
Money

Sum

of

X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING

COMES NOW the Defendant, by the undersigned counsel, and unto this
Honorable Court, respectfully moves:

1. The Complaint in this matter was served on Edgardo S. Santos on


_______________________, making his Answer due on ____________________;

2. Due to the scheduling logistics of undersigned counsel, Defendant need


and respectfully request a short extension in which to file his Answer to the
Complaint;

3. Undersigned counsel request a two-week extension, making his Answer


due on ___________________.

WHEREFORE, Defendant herein and undersigned counsel respectfully


request a two-week extension from__________ to _________ in which to file their
Answer to the Complaint.
Quezon City, __________________

ATTY. LOUISE MARIE S. PEREZ


Counsel for Defendant
Citibank Tower Eastwood City Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

NOTICE OF HEARING
To: Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
Greetings:
Please take notice that on Friday, _______________, at 8:00 oclock A.M., or as
soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing Motion for
Extension of Time to File Responsive Pleading.

ATTY. LOUISE MARIE S. PEREZ


Counsel for Defendant
Citibank Tower Eastwood City
Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City

EXPLANATION
The foregoing Motion for Extension of Time to File Responsive Pleading
has been served on Plaintiffs counsel by registered mail due to lack of time and
personnel to effect personal delivery.

ATTY. LOUISE MARIE S. PEREZ


Republic of the Philippines
METROPOLITAN TRIAL COURT
National Capital Judicial Region
Branch ____, Quezon City

Defendant.

NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS

CIVIL CASE NO. _____


For: Collection of a
Money

Sum

X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
MOTION FOR BILL OF PARTICULARS

COMES NOW the Defendant, by the undersigned counsel, and unto this
Honorable Court, respectfully alleges:

1. That the plaintiff's complaint in its paragraphs 3 to 6 alleges:

of

3.

That the above-named spouse of Plaintiff is the erstwhile business partner

of the defendant from year 2007 to 2009;


4.

That in the course of their business, the plaintiffs spouse made financial

contributions through the request and assurances of the defendant that such amount will
be repaid. That however, after several months and upon inquiry, plaintiffs spouse found
out that defendant misappropiated the financial investments made for his own personal
use. That despite demands, defendant failed to remit to and/or settle with the plaintiffs
spouse the aggregate amount of Ninety Eight Thousand Seven Hundred Pesos
(P98,700.00);
5.

That in recognition of defendants obligation in favor of plaintiffs spouse,

the former executed an Acknowledgement of Debt in favor of the plaintiff on January 26,
2008, a photocopy of which is attached hereto as Annex A;
6.

That by reason of the kindness and generosity of plaintiffs spouse,

defendants obligation through the Acknowledgement was reduced to the sum of Sixty
Thousand Pesos (P60,000.00), and transferred in favor of the plaintiff as formalized n a
duly-notarized Loan Agreement entered by and between the plaintiff and the defendant on
January 29 2008, a photocopy of which is hereto attached as Annex B;

2. That said allegations are insufficient and defective in that it fails to specify
the genuineness and authenticity of documents and the exact circumstances
which actually prevailed;

3. That a more definite statement on the matter as above indicated is


necessary in order to enable the defendant to properly prepare his responsive
pleading.

WHEREFORE, it is respectfully prayed that an Order be issued by this


Honorable court requiring the Plaintiff to make more definite and certain his
complaint in the particulars above indicated.

Quezon City, __________________

ATTY. LOUISE MARIE S. PEREZ


Counsel for Defendant
Citibank Tower Eastwood City Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

NOTICE OF HEARING

To: Atty. Angelico Zenon M. Delos Reyes


Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City

Greetings:
Please take notice that on Friday, _______________, at 8:00 oclock A.M., or as
soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing Motion for
Bill of Particulars.

ATTY. LOUISE MARIE S. PEREZ


Counsel for Defendant
Citibank Tower Eastwood City
Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City

EXPLANATION
The foregoing Motion for Bill of Particulars has been served on the
Plaintiffs counsel by registered mail due to lack of time and personnel to effect
personal delivery.

ATTY. LOUISE MARIE S. PEREZ

Republic of the Philippines


METROPOLITAN TRIAL COURT
National Capital Judicial Region
Branch ____, Quezon City

Defendant.

NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS

CIVIL CASE NO. _____


For: Collection of a
Money

Sum

X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
SECOND MOTION FOR EXTENSION OF TIME
TO FILE RESPONSIVE PLEADING

COMES NOW the Defendant, by the undersigned counsel, and unto this
Honorable Court, respectfully moves:

of

1. That the extended deadline for the filing of the Defendants Answer is
already tomorrow ________________ which was granted by this Honorable Court
as per Order dated ______________;

2. That the undersigned counsel was suddenly stricken by the dreadful and
painful sore-eyes infection last two days ago, Defendant need and respectfully
request another short extension in which to file his Answer to the Complaint;

3. Undersigned counsel hereby request a two-week extension, making their


Answer due on ___________________.

WHEREFORE, Defendant herein and undersigned counsel respectfully


request another two-week extension from__________ to _________ in which to
file their Answer to the Complaint.
Quezon City, __________________
ATTY. LOUISE MARIE S. PEREZ
Counsel for Defendant
Citibank Tower Eastwood City Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

NOTICE OF HEARING

To: Atty. Angelico Zenon M. Delos Reyes


Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
Greetings:
Please take notice that on Friday, _______________, at 8:00 oclock A.M., or as
soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing Second
Motion for Extension of Time to File Responsive Pleading.

ATTY. LOUISE MARIE S. PEREZ


Counsel for Defendant
Citibank Tower Eastwood City
Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City

EXPLANATION
The foregoing Second Motion for Extension of Time to File Responsive
Pleading has been served on Plaintiffs counsel by registered mail due to lack of
time and personnel to effect personal delivery.

ATTY. LOUISE MARIE S. PEREZ


Republic of the Philippines
METROPOLITAN TRIAL COURT
National Capital Judicial Region
Branch ____, Quezon City

Defendant.

NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS

CIVIL CASE NO. _____


For: Collection of a
Money

X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
FINAL MOTION FOR EXTENSION OF TIME
TO FILE RESPONSIVE PLEADING

Sum

of

COMES NOW the Defendant, by the undersigned counsel, and unto this
Honorable Court, respectfully moves:

1. That the second extended deadline for the filing of the Defendants
Answer is already tomorrow ________________ which was granted by this
Honorable Court as per Order dated ______________;

2. That the undersigned counsel, not yet fully recovered from the dreadful
sore-eyes, conducted an initial interview with the Defendant for the preparation
of his Answer but yesterday, when the draft pleading will be shown for
comments, Defendant failed to arrive at undersigneds office because the latter
contracted also the same disease;

3. Undersigned counsel hereby requests a short two-week extension, making


their Answer due on ___________________;

4. That this final request for extension of the hearing is not for the purpose
of delaying the disposition of the case.

WHEREFORE, Defendant herein and undersigned counsel respectfully


request another two-week extension from__________ to _________ in which to
file their Answer to the Complaint.
Quezon City, __________________

ATTY. LOUISE MARIE S. PEREZ


Counsel for Defendant
Citibank Tower Eastwood City Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

NOTICE OF HEARING

To: Atty. Angelico Zenon M. Delos Reyes


Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
Greetings:
Please take notice that on Friday, _______________, at 8:00 oclock A.M., or as
soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing Final Motion
for Extension of Time to File Responsive Pleading.

ATTY. LOUISE MARIE S. PEREZ


Counsel for Defendant
Citibank Tower Eastwood City
Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City

EXPLANATION
The foregoing Final Motion for Extension of Time to File Responsive
Pleading has been served on Plaintiffs counsel by registered mail due to lack of
time and personnel to effect personal delivery.

ATTY. LOUISE MARIE S. PEREZ

Republic of the Philippines


METROPOLITAN TRIAL COURT
National Capital Judicial Region
Branch ____, Quezon City

Defendant.

NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS

CIVIL CASE NO. _____


For: Collection of a
Money

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

MOTION TO DECLARE DEFENDANT IN DEFAULT

Sum

of

PLAINTIFF, thru the undersigned Counsel, unto this Honorable Court,


respectfully alleges:
1. Defendant was served Summons together with a copy of the Complaint
and annexes thereto in the above-entitled case at his address # 15 Bohol St.,
Barangay Horseshoe, Quezon City, where he was residing;
2. Mr. Steven R. Lucas served the Summons on ___________ per Sheriff's
Return of same date attached herewith as Annex A;
3. Under Sec. 1 Rule 11 of the Revised Rules of Court of the Philippines,
the defendant has fifteen (15) days after service of Summons to file his answer to
the complaint. More than fifteen (15) days has lapsed since Summons was served
upon the defendant and up this date, defendant has not filed his answer or any
responsive pleading for that matter;
4. Notwithstanding the fact that the defendant requested and filed three
Motions for extensions of time, still, they failed to file an Answer on the deadline
approved by this Honorable Court as per Order dated ______________ attached
herewith as Annex B.
IN VIEW of the failure of the defendant to file his answer or any
responsive pleading, plaintiff respectfully prays to the Honorable Court to
declare the defendant in default pursuant to Sec. 3 Rule 9 of the Rules of Court.
Other reliefs just and equitable under the premises are likewise prayed for.
Quezon City, ______________________

Atty. ANGELICO ZENON M. DELOS REYES


Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave., Libis, Quezon City
Roll No. 76430 IBP No. 352980 dated 1-2-08
MCLE Compliance No. 11-00043527

NOTICE OF HEARING

To: Atty. Louise Marie S. Perez


Counsel for the Defendant
Citibank Tower Eastwood City
Bagumbayan, Quezon City
Greetings:
Please take notice that on Friday, _______________, at 8:00 oclock A.M., or as
soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing Motion to
Declare Defendant in Default.

ATTY. ANGELICO ZENON M. DELOS REYES


Counsel for Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
Roll No. 76430 IBP No. 352980 dated 1-2-08
MCLE Compliance No. 11-00043527

COPY FURNISHED:
Atty. Atty. Louise Marie S. Perez
Counsel for the Defendant
Citibank Tower Eastwood City
Bagumbayan, Quezon City

EXPLANATION

The foregoing Motion to Declare Defendant in Default has been served on


Defendants counsel by registered mail due to lack of time and personnel to effect
personal delivery.

Atty. ANGELICO ZENON M. DELOS REYES

Republic of the Philippines


METROPOLITAN TRIAL COURT
National Capital Judicial Region
Branch ____, Quezon City

Defendant.

NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS

CIVIL CASE NO. _____


For: Collection of a
Money

Sum

of

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

MOTION TO LIFT ORDER OF DEFAULT


COMES NOW the defendant, EDGARDO S. SANTOS thru the
undersigned counsel and unto this Honorable Court, respectfully avers:

1. That defendant and undersigned counsel was not able to timely file an
answer for the reason that both suffered a very infectious disease of sore-eyes
from _____________ upto _______________;

2. That undersigned counsel, despite the pain and misery managed to


prepare and draft the Answer but defendant himself suffered worst and was even
confined for three days. A doctors certificate, to attest the truthfulness of this
unfortunate event is hereby attached as Annex A;

3. That defendants Answer will be filed tomorrow already;

4. That both the defendant and the undersigned counsel is committed to


the speedy disposition of this case.

WHEREFORE, it is respectfully prayed that the order declaring the


defendant in default be lifted and that this Honorable Court allow the defendant
to file an answer to the plaintiffs complaint.
Quezon City,_____________
ATTY. LOUISE MARIE S. PEREZ
Counsel for Defendant
Citibank Tower Eastwood City Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

NOTICE OF HEARING

To: Atty. Angelico Zenon M. Delos Reyes

Counsel for the Plaintiff


Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
Greetings:
Please take notice that on Friday, _______________, at 8:00 oclock A.M., or as
soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing Motion to
Lift Order of Default.

ATTY. LOUISE MARIE S. PEREZ


Counsel for Defendant
Citibank Tower Eastwood City
Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City

EXPLANATION
The foregoing Motion to Lift Order of Default has been served on
Plaintiffs counsel by registered mail due to lack of time and personnel to effect
personal delivery.

ATTY. LOUISE MARIE S. PEREZ


Republic of the Philippines
METROPOLITAN TRIAL COURT
National Capital Judicial Region
Branch ____, Quezon City

NAPOLEON C. GATMAITAN
Plaintiff,

-versusEDGARDO S. SANTOS

Defendant.

CIVIL CASE NO. _____


For: Collection of a
Money

Sum

of

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

ANSWER

COMES NOW the defendant EDGARDO S. SANTOS thru the


undersigned counsel, respectfully alleges:

1. That he specifically denies under oath the genuineness and due


execution of the alleged Acknowledgement of Debt (Annex A) and Loan
Agreement (Annex B) attached to the plaintiffs complaint;

2. That the said two documents were fraudulently executed by the plaintiff
NAPOLEON C. GATMAITAN, the defendant EDGARDO S. SANTOS not
having executed any such promissory note in favor of the former, thus, the said
promissory note is null and void.

WHEREFORE, it is respectfully prayed that the plaintiffs complaint be


dismissed with costs against the plaintiff. The defendant further prays for such
other relief as the Honorable Court may deem just and equitable.

Quezon City,_____________

ATTY. LOUISE MARIE S. PEREZ


Counsel for Defendant
Citibank Tower Eastwood City Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

COPY FURNISHED:
Atty. Angelico Zenon M. Delos Reyes
Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City

VERIFICATION

I, EDGARDO S. SANTOS, of legal age, Filipino and with address at # 15


Bohol St., Barangay Horseshoe, Quezon City, having been duly sworn to in
accordance with law hereby depose and say:

1. That I am the Defendant in the above-entitled case; that I have caused


the preparation of the foregoing Answer Pleading; that all the allegations stated
therein are true and correct of my own knowledge and supported by authentic
documents;
2. That I have not commenced any other action or proceeding involving
the same issues is the Supreme Court, the Court of Appeals, or any other tribunal
or agency; that to the best of my knowledge, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, or any other tribunal or
agency; that there is no other action or proceeding which is either pending or
may have been terminated, and if I should thereafter learn that a similar action or
proceeding has been filed or is pending before the Supreme Court, the Court of
Appeals, or any tribunal or agency, I undertake to report that fact within five (5)
days there from to this Honorable Court.

EDGARDO S. SANTOS
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of _______ at


Quezon City affiant exhibiting to me her Community Tax Certificate No.
__________ issued in ___________ on ____________

NOTARY PUBLIC

Doc. No.________;
Page No.________;
Book No.________;
Series of ________;

Republic of the Philippines


METROPOLITAN TRIAL COURT
National Capital Judicial Region
Branch ____, Quezon City

Defendant.

NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS

CIVIL CASE NO. _____


For: Collection of a
Money

Sum

of

X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
MANIFESTATION AND MOTION TO WITHDRAW AS COUNSEL WITH
SUBSTITUTION OF COUNSEL

The Clerk of Court


Regional Trial Court of Quezon City
Branch _________

COMES NOW Atty. Louise Marie S. Perez, counsel of record for the
Defendant and unto this Honorable Court respectfully moves to withdraw as
counsel for Defendant with the express consent of the defendant as shown in this
motion.

That in substitution thereof, Atty. Corazon Alma T. Soliman whose


services have been retained by Defendant, hereby enters her appearance as
counsel for the Defendant.

That upon the approval of this Honorable Court, all pleadings, notices and
papers in connection with the above entitled case be addressed to the new
counsel, Atty. Corazon Alma T. Soliman, with address at 13th floor, Will Tower
Mother Ignacia St., Barangay South Triangle, Quezon City.

Quzon City, _________________

ATTY. LOUISE MARIE S. PEREZ

Former Counsel for Defendant


Citibank Tower Eastwood City
Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

ATTY. CORAZON ALMA T. SOLIMAN


13th floor, Will Tower
Mother Ignacia St.,
Barangay South Triangle, Quezon City
Roll No. 87639 IBP No. 866551 dated 1-7-10
MCLE Compliance No. 11-00083769
WITH DEFENDANTS CONSENT

EDGARDO S. SANTOS

NOTICE OF HEARING

To: Atty. Angelico Zenon M. Delos Reyes


Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
Greetings:
Please take notice that on Friday, _______________, at 8:00 oclock A.M., or as
soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing
Manifestation and Motion to Withdraw as Counsel with Substitution of Counsel.

ATTY. LOUISE MARIE S. PEREZ


Counsel for Defendant
Citibank Tower Eastwood City
Bagumbayan, Quezon City
Roll No. 87432 IBP No. 863992 dated 1-5-10
MCLE Compliance No. 11-00083469

COPY FURNISHED:

Atty. Angelico Zenon M. Delos Reyes


Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City

EXPLANATION
The foregoing Manifestation and Motion to Withdraw as Counsel with
Substitution of Counsel has been served on Plaintiffs counsel by registered mail
due to lack of time and personnel to effect personal delivery.

ATTY. LOUISE MARIE S. PEREZ

Republic of the Philippines

METROPOLITAN TRIAL COURT


National Capital Judicial Region
Branch ____, Quezon City

Defendant.

NAPOLEON C. GATMAITAN
Plaintiff,
-versusEDGARDO S. SANTOS

CIVIL CASE NO. _____


For: Collection of a
Money

Sum

of

X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
MOTION FOR EXECUTION OF JUDGMENT

COMES NOW the Plaintiff, by the undersigned counsel, and unto this
Honorable Court, respectfully moves for the execution of judgment under the
following premise:
1. That a decision has been rendered in this case on August 1, 2011, in favor of
the Plaintiff and against the Defendant;
2. That the period for appeal has already expired without the Defendant
having perfected an appeal from said decision;
3. That said decision is now final and executory.

WHEREFORE, it is respectfully prayed that an Order be issued for the


execution of the above judgment.
Quezon City, ___________________.

Atty. ANGELICO ZENON M. DELOS REYES


Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave., Libis, Quezon City
Roll No. 76430 IBP No. 352980 dated 1-2-08
MCLE Compliance No. 11-00043527

NOTICE OF HEARING
TO: ATTY. CORAZON ALMA T. SOLIMAN
Counsel for the Defendant
13th floor, Will Tower
Mother Ignacia St.,
Barangay South Triangle, Quezon City
Greetings:
Please take notice that on Friday, _______________, at 8:00 oclock A.M., or as
soon thereafter as counsel may be heard, the undersigned will ask Branch _____
of the Regional Trial Court of Quezon City to approve the foregoing Motion for
Execution of Judgment.

ATTY. ANGELICO ZENON M. DELOS REYES


Counsel for the Plaintiff
Phoenix Sun Business Park E. Rodriguez Jr. Ave.,
Libis, Quezon City
Roll No. 76430 IBP No. 352980 dated 1-2-08
MCLE Compliance No. 11-00043527

COPY FURNISHED:
ATTY. CORAZON ALMA T. SOLIMAN
Consel for the Defendant
13th floor, Will Tower
Mother Ignacia St.,
Barangay South Triangle, Quezon City
EXPLANATION
The foregoing Motion for Execution of Judgment has been served on
Defendants counsel by registered mail due to lack of time and personnel to effect
personal delivery.

ATTY. ANGELICO ZENON M. DELOS REYES

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