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Sample Forms in Practical Exercises

This document contains sample legal forms used in the Philippines for practical exercises, including: 1. A demand letter regarding a bounced check. 2. An authorization letter allowing someone to pick up a deed of cancellation. 3. Basic forms for a lease agreement, deed of sale for real property, and deed of sale for a vehicle. 4. A special power of attorney authorizing someone to sell stock. 5. A verification and certification against forum shopping for a legal case. The document provides templates for common legal documents and forms used in the Philippines for educational purposes.

Uploaded by

Peter Allan
Copyright
© © All Rights Reserved
Available Formats
Download as PDF, TXT or read online on Scribd
0% found this document useful (0 votes)
146 views

Sample Forms in Practical Exercises

This document contains sample legal forms used in the Philippines for practical exercises, including: 1. A demand letter regarding a bounced check. 2. An authorization letter allowing someone to pick up a deed of cancellation. 3. Basic forms for a lease agreement, deed of sale for real property, and deed of sale for a vehicle. 4. A special power of attorney authorizing someone to sell stock. 5. A verification and certification against forum shopping for a legal case. The document provides templates for common legal documents and forms used in the Philippines for educational purposes.

Uploaded by

Peter Allan
Copyright
© © All Rights Reserved
Available Formats
Download as PDF, TXT or read online on Scribd
You are on page 1/ 14

JURISTS BAR REVIEW CENTER™

SAMPLE FORMS IN PRACTICAL EXERCISES

A.1. DEMAND LETTER

1 April 2019

JUAN DEBTOR
[Address]

Dear Mr. Debtor:

We write in behalf of our client Jose Creditor regarding the check you issued to him dated 15
March 2019 in the amount of ₱700,000, drawn against Bank of the Philippine Islands, Zapote,
Las Piñas City Branch. Upon presentment for payment, the same was dishonored for
reason of “account closed.”

Demand is hereby made upon you to pay to our client the amount of the check within 5 days
from receipt of this letter. Otherwise we shall file against you the criminal complaint for
violation of the Bouncing Checks Law without further notice and demand.

Please give this matter your immediate attention.

Yours truly,

ATTY. ANDRES MAGDAMIT


Counsel for Jose Creditor
[Address of Counsel]

A.2. AUTHORIZATION LETTER

BANK OF THE PHILIPPINE ISLANDS


[Address]

Ladies and Gentlemen:

This serves to authorize the bearer SUSAN AGENTE to pick up the deed of cancellation of
real estate mortgage over my property covered by TCT No. 123456, located in Imus, Cavite.

Please find attached a copy of my Driver’s License No. 7890123.

Thank you for your attention in this matter.

Yours truly,

JOSEPH PRINCIPALI
[Address]

2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 1 of 14
B.1. SIMPLE LEASE CONTRACT

CONTRACT OF LEASE

I, (full name of lessor), of legal age, single, with residence at


______________________, do hereby LEASE unto (full name of lessee) of legal age, single,
with residence and postal address at ____________________ that certain building, together
with the lot on which it stands, situated at ____________, and more particularly described as
follows, to wit:

(Technical Description of
Building and Lot)

of which lot and building I am the registered owner, my title thereto being evidenced by
Transfer Certificate of Title No. ______, of the Registry of Deeds of _________.

That the term of this lease is for _________ years from and after the execution of this
contract of lease.

And I, (full name of lessee), do hereby bind myself and promise to pay the said lessor
at the latter’s residence a monthly rental of P_________ during the first five days of each and
every month.

IN WITNESS WHEREOF, the parties have signed this agreement on ___________at


___________________.

____________________ ____________________
LESSOR LESSEE

SIGNED IN THE PRESENCE OF:


_________________________ _____________________

(ACKNOWLEDGMENT)

B.2. SIMPLE SALE OF REALTY

DEED OF SALE

I, ___________________________, Filipino, single/married to


_____________________, of legal age, with residence at _________________________, for
and in consideration of the sum of P_________________ to me in hand paid by (full name of
vendee), Filipino, of legal age, with residence at _________________________, do hereby
SELL, TRANSFER AND CONVEY, absolutely and unconditionally, in favor of the said
___________, that certain parcel of land, particularly described as follows to wit:

(Technical description)

of which I am the registered owner as evidenced by Transfer Certificate of Title No. ______
issued by the Registry of Deeds of ____________, free from all liens and encumbrances.

2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 2 of 14
IN WITNESS WHEREOF, I have signed this Deed of Sale, on ___________ at
______________________.

________________________
Vendor

TIN ________________

SIGNED IN PRESENCE OF:

____________________________ ___________________________

(ACKNOWLEDGMENT)

B.3. SIMPLE SALE OF PERSONAL PROPERTY (CAR)

DEED OF ABSOLUTE SALE

I, JUAN A. DELA CRUZ, of legal age, single, Filipino, with residence at 123 Northville
Homes, Molino, Bacoor City, Cavite, in consideration of the sum of P400,000 which I have
received from the Buyer, PEDRO A. SANTOS, do hereby sell and transfer to him the motor
vehicle particularly described as follows:

MAKE: MITSUBISHI
TYPE: AUV
MODEL: ADVENTURE 2008
ENGINE NO.: 12345
SERIAL NO.: 67890

IN WITNESS WHEREOF, I hereby sign this Deed of Sale on 1 April 2017 at Bacoor
City, Cavite.

JUAN A. DELA CRUZ

(Acknowledgment)

C. SPECIAL POWER OF ATTORNEY

SPECIAL POWER OF ATTORNEY

I, JOSEPH PRINCIPALI, Filipino, of legal age, and a resident of No. 7 M. Fernandez


St., BF Resort Village, Las Piñas City, do hereby name, constitute and appoint SUSAN
AGENTE of the Agente & Agente Law Office, Filipino, of legal age and with office address at
2/F Azucena Arcade, 255 Alabang-Zapote Road, Las Piñas City to be my true and lawful
attorney-in-fact, for me and in my name, place and stead and to do the following:

Sell and/or encumber my shares of stock in Manila Water Corporation, whether in my


name or held in the name of my broker, BPI Securities, Inc., for my benefit, under such terms
as he may deem suitable and proper.

HEREBY GIVING AND GRANTING unto my said attorney-in-fact full power and
authority whatsoever requisite or necessary or proper to be done in and about the premises
2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 3 of 14
as full to all intents and purposes as I might and could lawfully do if personally present, with
power of substitution and revocation, and hereby, ratifying and confirming all that my said
attorney or her substitute shall lawfully do or cause to be done under and by virtue of these
presents.

IN WITNESS WHEREOF, I have hereunto set my hand this ___ August 2018 at Las
Piñas City.

JOSEPH PRINCIPALI

SIGNED IN THE PRESENCE OF:

_________________________ _________________________

REPUBLIC OF THE PHILIPPINES)


LAS PINAS CITY ) S.S.

ACKNOWLEDGMENT

BEFORE ME, a notary public, on ___ August 2018 at Las Pinas City, personally
appeared JOSEPH PRINCIPALI and exhibited to me his SSS No. 06-0958807-5 issued by
Social Security System. Known to me and to me known to be the same person who
executed the foregoing Special Power of Attorney and he acknowledged before me that the
same is his own free and voluntary act and deed.

WITNESS MY HAND AND SEAL, on the date and place above-written.

Doc. No. _____


Page No._____
Book No. _____
Series of 2018.

D. VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, JUAN DELA CRUZ, of legal age, Filipino, married/single and resident of 1234
Masayahin St. Brgy. 1, Sta. Cruz, Manila, hereby depose and state under oath that:

1. I am the Petitioner in the above-stated case.

2. I have caused the preparation of the foregoing Petition.

3. I have read the contents thereof and the facts stated therein are true and
correct of our personal knowledge and/or on the basis of copies of documents and
records in our possession.

4. I have not heretofore commenced any action or filed any claim involving the
same issues in any court, tribunal or quasi-judicial agency, and to the best of our
knowledge, no such action or claim is pending therein.

2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 4 of 14
5. If I should thereafter learn that the same or similar action or claim has been
filed or is pending, we shall report this fact within five (5) days therefrom to this
Honorable Court.

AFFIANT

SUBSCRIBED AND SWORN to before me on _____________________ at


_____________________, Affiant exhibiting to me his Driver’s License No.
____________ valid until ______________.

Doc. No. __________


Page No. __________ NOTARY PUBLIC
Book No. __________ (Notarial Commission)
Series of 2018.

E. NOTICE OF HEARING & EXPLANATION

NOTICE OF HEARING

To:

ATTY. JOHN SMITH


Counsel for the Plaintiff

ATTY. JUAN DELA CRUZ


CLERK OF COURT
RTC, Branch 21
City of Manila

Greetings:

Please take notice that the undersigned counsel for the Defendant shall submit
the foregoing motion for approval of the Honorable Court on 17 February 2019 at
1:30 pm.

ATTY. JUANA CRUZ

EXPLANATION

Due to the distance to the Plaintiff’s counsel and to manpower limitations, the
undersigned counsel for the Defendant is constrained to file and/or serve this
Motion by registered mail.

ATTY. JUANA CRUZ

2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 5 of 14
F. JUDICIAL AFFIDAVIT

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH 45, QUEZON CITY

JOSE CREDITOR, Civil Case No. 19-12345


Plaintiff,

-versus- For: Sum of Money

JUAN DEBTOR,
Defendant.
x-----------------------------------------------------x

JUDICIAL AFFIDAVIT OF JOSE CREDITOR

Note: Questions propounded by the Plaintiff’s counsel, Atty. Rufo Enrique, with address at
___________ and the answers made by the witness Jose Creditor. The examination was
conducted by Atty. Enrique at ______________________, Makati City.

I, JOSE CREDITOR, 37 years of age, Filipino citizen, with residence address at


____________________, Makati City, Metro Manila, and with occupation of businessman, do
hereby depose and state under oath that:

Q1 Mr. Creditor, are you fully conscious that you are answering the questions asked of you
under oath and that you will be liable for false testimony or perjury if you do not answer
truthfully?

A Yes, sir.

Q2 Are you the Plaintiff in this case?

A Yes.

Q3 Do you know the Defendant in this case?

A Yes.

Q4 Why do you know the Defendant?

A Because we have been friends since grade school.

Q5 On 3 March 2018, did the Defendant visit your house?

A Yes.

Q6 Why did he visit your house?

A He just dropped by uninvited. Since we were close friends, I invited him in and we had
a talk.

2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
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Q7 What did you talk about?

A We talked about old times. And then he asked me if I could lend him P700,000 for a
business he was putting up.

Q8 Did you lend him the P700,000?

A Yes. But I asked that he execute a promissory note in my favor as proof of the loan
and that the due date should be one year or on 3 March 2019.

Q9 What did he say to your requirement?

A He agreed and he executed the promissory note in my favor promising to pay the loan
on 3 March 2019.

Q10 After he had executed the promissory note, what happened?

A I gave to him the P700,000 and he gave to me the promissory note.

Q11 I’m showing to you this Promissory Note dated 3 March 2018 in the amount of
P700,000 and payable on 3 March 2019 without need of notice or demand. Is this the
promissory note which was executed by Defendant?

A Yes.

Q12 I’m showing to you this signature on the promissory note above the printed name Juan
Debtor. Is this the signature of the Defendant?

A Yes.

Q13 How do you know that it is his signature?

A He signed the promissory note in front of me and besides I’m familiar with his signature
since we are long-time friends and I’ve seen him sign several times.

ATTY. ENRIQUE: Your Honor we move that the Promissory Note be marked as Exhibit A
and that the Defendant’s signature thereon be sub-marked as Exhibit A-1.

Q14 What happened if any when the due date arrived?

A I called up the Defendant and demanded payment, but he said he could not pay
because his business had folded up.

Q15 What was your response to his statement?

A I said I’m sorry about his business but he should repay me because one year is long
enough and I need the money.

Q16 What was his response to your statement?

A He said he was so sorry but he could not repay me.

Q17 What did you do after he said he could not repay you?

A I engaged Atty. Rufo Enrique to file a collection case against him, which Atty. Enrique
did.

2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 7 of 14
Q18 Has the Defendant paid his loan obligation to you?

A No, up to now he has not paid me a single centavo on his loan obligation.

Q19 What damages are you seeking from the Defendant?

A Apart from the repayment of the P700,000, I am also seeking interest by way of
damages at the rate of 6% per annum starting from 3 March 2019 until payment.

JOSE CREDITOR

SUBSCRIBED AND SWORN to before me on ______ June 2019 at


________________, Affiant exhibiting to me his Driver’s License No.
_______________________ valid until ____________________.

Doc. No. _____ NOTARY PUBLIC


Page No. _____ (Notarial Commission)
Book No. ______
Series of 2019

ATTESTATION

I, RUFO ENRIQUE, after having being duly sworn in accordance with law, hereby
attest that I conducted the foregoing examination of JOSE CREDITOR; that I faithfully
recorded the questions that I asked and the corresponding answers that the affiant gave; that
neither I nor any person present or assisting me or the witness coached him regarding his
answers, and that I am aware that a false attestation shall subject me to disciplinary action,
including disbarment.

RUFO ENRIQUE

SUBSCRIBED AND SWORN to before me on ______ June 2019 at


________________, Affiant exhibiting to me his Driver’s License No.
________________valid until ____________________.

Doc. No. _____ NOTARY PUBLIC


Page No. _____ (Notarial Commission)
Book No. ______
Series of 2019

G.1 NOTARIAL CERTIFICATE: JURAT

SUBSCRIBED AND SWORN to before me on _____________________ at


_____________________, Affiant exhibiting to me his Driver’s License No. ____________
valid until ______________.

Doc. No. ______ JUAN DELA CRUZ


Page No. ______ Commission LP-18-1231

1
See NOTES.
2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
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Book No.______ Until 31 December 2019
Series of ______ Pall Mall Bldg., Las Pinas City
PTR 1234/1-9-18/Las Pinas City
IBP No. 4567/1-9-18/Pasig City
Roll No. 34567/4 June 1992
MCLE Compliance No. VI-0015071
Issued on 23 October 2018, Pasig City

G.2.1 NOTARIAL CERTIFICATE: ACKNOWLEDGMENT (one-page document)

BEFORE me, a Notary Public for and in the City of Las Pinas, on ___________ personally
appeared JOSE REYES who exhibited to me his Driver’s License No. __________ valid until
_________________, known to me to be the same person who executed the foregoing lease contract
which he acknowledged before me as his free and voluntary act and deed.

WITNESS MY HAND AND SEAL at the place and date above written.

Doc. No. ______ JUAN DELA CRUZ


Page No. ______ Commission LP-18-123
Book No.______ Until 31 December 2019
Series of ______ Pall Mall Bldg., Las Pinas City
PTR 1234/1-9-18/Las Pinas City
IBP No. 4567/1-9-18/Pasig City
Roll No. 34567/4 June 1992
MCLE Compliance No. VI-0015071
Issued on 23 October 2018, Pasig City

G.2.2 NOTARIAL CERTIFICATE: ACKNOWLEDGMENT [2 or more pages]

BEFORE ME, a Notary Public for and in Las Pinas City, on ____________________,
personally appeared the following:

Name Gov’t ID No. Valid until


____________________ _____________ _______________

____________________ _____________ _______________

all known to me and to me known to be the same persons who executed the foregoing Agreement and
they acknowledged to me that the same is their free and voluntary act and deed. This instrument,
consisting of 3 pages, including the page on which this acknowledgment is written, has been signed
on the left margin of each and every page hereof by the concerned parties and their witnesses, and
sealed with my notarial seal.

WITNESS MY HAND AND SEAL at the place and date above written.

Doc. No. ______ JUAN DELA CRUZ


Page No. ______ Commission LP-18-123
Book No.______ Until 31 December 2019
Series of ______ Pall Mall Bldg., Las Pinas City
PTR 1234/1-9-18/Las Pinas City
IBP No. 4567/1-9-18/Pasig City
Roll No. 34567/4 June 1992
MCLE Compliance No. VI-0015071
Issued on 23 October 2018, Pasig City

2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 9 of 14
NOTES:

1. Below notary public, you can just write: “(Notarial Commission)” instead of the full
notarial commission details (which are quite long) unless instructed to write the notarial
commission details.
2. When pressed for time, you can just write “(Jurat)” or “(Acknowledgment).” If you have
adequate time, we advise you write out fully the jurat and acknowledgment.

H.1. MOTION FOR EXTENSION OF TIME

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Manila, Branch 45

PETER PAN,
Plaintiff,

-versus- Civil Case No. 19-1234


For: Sum of Money
CAPTAIN HOOK,
Defendant,
x--------------------------------x

MOTION FOR EXTENSION OF


TIME TO FILE ANSWER

Defendant, through the undersigned counsel, most respectfully avers that:

1. Defendant received the summons and complaint on 2 April 2019. Defendant has
fifteen days or until 17 April 2019 within which to file his answer or other responsive paper.

2. Due however to his heavy caseload, the undersigned counsel would be unable to
file the answer or responsive paper by 17 April 2019.

WHEREFORE Defendant prays for an extension of 15 days from 17 April 2019 or until
2 May 2019 within which to file his answer.

Las Piñas City for Manila, 15 April 2019.

ATTY. ROBERT STEVENSON


Counsel for Defendant
2/F Pentax Building
235 Alabang-Zapote Road, Las Pinas City
MCLE Compliance No. V- 0012345
Issued on 10 October 2016
PTR No. 67891/1-2-2019/Las Piñas City
IBP No. 456789/1-2-2019/Pasig City
Roll No. 37840/4 June 1992

2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 10 of 14
NOTICE

TO:

QUIBBLE & QUIBBLE


Counsel for the Plaintiff

ATTY. JUAN DELA CRUZ


Clerk of Court
RTC-Manila, Branch 45

Greetings:

Please take notice that the Defendant shall submit the foregoing motion for the
immediate consideration and approval of the court without further arguments, the motion
being non-litigious.

ATTY. ROBERT STEVENSON

EXPLANATION

Due to the distance to Plaintiff’s counsel and to lack of personnel, the undersigned
counsel for Defendant was constrained to serve a copy of this motion upon Plaintiff’s counsel
by registered mail.

ATTY. ROBERT STEVENSON

COPY FURNISHED:

QUIBBLE & QUIBBLE


Counsel for Plaintiff
3/F Anime Tower
123 C. Aguila Street
Manila

H.2. MOTION TO DISMISS

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Manila, Branch 45

PETER PAN,
Plaintiff,

vs. Civil Case No. 19-1234


For: Sum of Money
CAPTAIN HOOK,
Defendant,
x-----------------------x
2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 11 of 14
MOTION TO DISMISS

Defendant, through the undersigned counsel, most respectfully avers that:

1. The allegations of the Complaint show that both the Plaintiff and the Defendant are
residents of Manila.

2. The dispute however had not been referred for mediation and conciliation before
the barangay captain and/or council, which is a condition precedent for filing the case as
required under the Local Government Code. No certificate to file action coming from the
barangay has been attached to the Complaint.

WHEREFORE, it is most respectfully prayed that the complaint be dismissed for failure
to comply with a condition precedent.

Las Piñas City for Manila, 2 May 2019.

ATTY. ROBERT STEVENSON


Counsel for Defendant
2/F Pentax Building
235 Alabang-Zapote Road, Las Pinas City
MCLE Compliance No. V- 0012345
Issued on 10 October 2016
PTR No. 67891/1-2-2019/Las Piñas City
IBP No. 456789/1-2-2019/Pasig City
Roll No. 37840/4 June 1992

NOTICE OF HEARING
To:

QUIBBLE & QUIBBLE


Counsel for the Plaintiff

ATTY. JUAN DELA CRUZ


Clerk of Court
RTC-Manila, Branch 45

Greetings:

Please take notice that the undersigned counsel for the Defendant shall submit the
foregoing motion for the approval of the Honorable Court on 10 May 2019 at 1:30 pm.

ATTY. ROBERT STEVENSON

EXPLANATION

Due to the distance to the Plaintiff’s counsel and to manpower limitations, the
undersigned counsel for the Defendant was constrained to file and/or serve this Motion by
registered mail.

ATTY. ROBERT STEVENSON


2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 12 of 14
COPY FURNISHED:

QUIBBLE & QUIBBLE


Counsel for Plaintiff
3/F Anime Tower
123 C. Aguila Street
Manila

H.3. MOTION TO DECLARE DEFENDANT IN DEFAULT

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Manila, Branch 45

HENRY JEKYLL,
Plaintiff,

vs. Civil Case No. 19-1234


For: Sum of Money
EDWARD HYDE,
Defendant,
x-----------------------x

MOTION TO DECLARE DEFENDANT IN DEFAULT

Plaintiff, through the undersigned counsel, most respectfully avers that:

1. The Defendant was served with summons and the complaint on 2 May 2019, as
shown by the Sheriff’s return of even date.

2. Up to now, or more than 15 days from the service of the summons and complaint
upon him, the Defendant has not filed any answer.

WHEREFORE, it is most respectfully prayed that the Defendant be declared in default


and that the Honorable Court proceed to render judgment granting the Plaintiff such relief as
the Complaint may warrant.

Manila, 29 May 2019.

ATTY. FRANK N. STEIN


Counsel for Plaintiff
3/F Anime Tower
123 C. Aguila Street
Manila
MCLE Compliance No. V- 0012345
Issued on 10 October 2016
PTR No. 67891/1-2-2019/Las Piñas City
IBP No. 456789/1-2-2019/Pasig City
Roll No. 37840/4 June 1992

2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 13 of 14
NOTICE OF HEARING

To:

ATTY. ROBERT STEVENSON


Counsel for the Defendant

ATTY. JUAN DELA CRUZ


Clerk of Court
RTC-Manila, Branch 45

Greetings:

Please take notice that the undersigned counsel for the Plaintiff shall submit the foregoing
motion for the approval of the Honorable Court on 7 June 2019 at 1:30 pm.

ATTY. FRANK N. STEIN

EXPLANATION

Due to the distance to the Defendant’s counsel and to manpower limitations, the
undersigned counsel for the Plaintiff was constrained to file and/or serve this Motion by
registered mail.

ATTY. FRANK N. STEIN

COPY FURNISHED:

ATTY. ROBERT STEVENSON


Counsel for Defendant
2/F Pentax Building
235 Alabang-Zapote Road, Las Piñas City

-oOo-

2019 Sample Forms in Practical Exercises by Prof. Manuel R. Riguera for Jurists Bar Review Center™. © 2019 by Jurists Review
Center Inc. Unauthorized reproduction, use, or dissemination, uploading or downloading is strictly prohibited and shall be prosecuted to
the full extent of the law, including administrative complaints with the Office of the Bar Confidant, Supreme Court. Page 14 of 14

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