REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF ILOILO

Sixth Judicial Region
BRANCH 33
Iloilo City

ALEXANDER SISON, Civil Case No. 2016-29016

Plaintiff, FOR:COLLECTION OF SUM OF MONEY
-versus-

JUAN JAMERO,
Defendant.
x- - - - - - - - - - - - - - - - -x

MOTION TO DECLARE DEFENDANT IN DEFAULT

Plaintiff, by counsel and unto this Honorable Court, respectfully states

1. The records of the Honorable Court show that Defendant was served with copy of the
summons and of the complaint, together with annexes thereto on 15 January 2017.

2. Upon verification however, the records show that Defendant Juan Jamero has failed to file
his Answer within the reglementary period specified by the Rules of Court despite the service
of the summons and the complaint;

3. As such, it is respectfully prayed that Defendant Juan Jamero be declared in default

pursuant to the Rules of Court and that the Honorable Court proceed to render judgment as
the complaint may warrant.

PRAYER

WHEREFORE, it is respectfully prayed that Defendant Juan Jamero be declared in

default pursuant to the Rules of Court and that the Honorable Court proceed to render
judgment as the complaint may warrant.

Other reliefs, just and equitable under the given circumstances, are likewise prayed for.

Given this 16th day of February 2017 at Jaro, Iloilo City, Philippines.

BY:

ATTY. SAMILLE JAN H. ABADA

Counsel for Plaintiff
IBP NO. 00107, 1/02/17, Iloilo City
PTR NO. 4899062, 1/02/17, Iloilo City
ROLL ATTORNEY NO. 15866
MCLE Comp. No III- 0018936, 1/02/17
NOTICE OF HEARING
HON. CLERK OF COURT
BR. 33
Greetings.

Kindly the foregoing motion to the attention of the Honorable Court immediately upon receipt
thereof and set the same for hearing on 20th day of February 2017, 8:30 A.M.

ATTY. SAMILLE JAN H. ABADA

Counsel for Plaintiff
IBP NO. 00107, 1/02/17, Iloilo City
PTR NO. 4899062, 1/02/17, Iloilo City
ROLL ATTORNEY NO. 15866
MCLE Comp. No III- 0018936, 1/02/17

Please be notified that the foregoing motion will be set for hearing this 20 th day of February
2017, 8:30 A.M.

COPY FURNISHED:

ATTY. SAMILLE JAN H. ABADA

Counsel for Plaintiff
IBP NO. 00107, 1/02/17, Iloilo City
PTR NO. 4899062, 1/02/17, Iloilo City
ROLL ATTORNEY NO. 15866
MCLE Comp. No III- 0018936, 1/02/17

RECEIVED BY:

ATTY. DAVE B. CONSEBIT

Counsel for the Respondent

Iloilo City, Philippines