REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Paranaque City, Branch
___________
Plaintiff,
-versus-

Civil Case No. _______

_________________
Defendant.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x

MANIFESTATION AND MOTION FOR SUBSTITUTION

The

HEIRS

OF

PLAINTIFF, through

undersigned

counsel

most

respectfully states:
1.

Plaintiff passed away on 24 October 2011 in Zurich, Switzerland as

may be gleaned from his death certificate which is attached and made an integral
part hereof as Annex A;
2.

The surviving heirs of the late are his spouse

and children

and

3.

Said surviving heirs manifest their desire to file a motion to

substitute

as plaintiffs in this case.

WHEREFORE, premises above considered, it is most respectfully prayed

that the Honorable Court allow their substitution of the deceased

as plaintiffs in

this case.
Other relief just and equitable under the premises are likewise prayed for.
Pasay City for Paranaque City, 27 January 2012.

Counsel for Heirs of

PTR No. -Pasay City, 01/02/12
IBP OR# PPLPM- 01/02/12
ROLL#
MCLE Compliance III , 13/16/11

NOTICE
The Clerk of Court
RTC

G R E E T I N G S:
Kindly submit the foregoing motion for the kind consideration of the
Honorable Court on Wednesday, 1 February 2012 at 8:30 a.m.

Copy furnished:

E X P LAN AT I O N
A copy of the foregoing motion was furnished the defendants counsel
through registered mail and thereafter filed by registered mail due to the absence
of a messenger to personally serve and file the same.

-2-