Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

Regional Trial Court
Branch 68
Pasig City

VANNY S. ACOSTA, Civil Case No: R-TAC-17-

0799-CV
Plaintiff,
FOR: RECOVERY OF
POSSESSION OF REAL
PROPERTY
- versus -

HUBERT JOHN F. ACOSTA,

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 February 20, 2018;

2. Upon verification however, the records show that Defendant

Hubert John F. Bautista 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 Huber John F.

Bautista 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 Hubert

John F. Bautista be declared in default pursuant to the Rules of Court
and that the Honorable Court proceed to render judgment as the
complaint may warrant.

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 Other reliefs, just and equitable under the given circumstances,
are likewise prayed for.
Pasig City, Metro Manila, Philippines, March 8, 20178.

ATTY. MARIZA R. OCAMPO

Counsel for the Plaintiff
Ocampo & Partners Law Offices
Ramos Bldg. Real St., Pasig City
Attys. Roll No. 12345/ 1-1-06
PTR No. 12345/1-03-17 Makati City, Metro Manila
IBP O.R. NO. 7654321/01-01-17, Manila Chapter
MCLE COMPLIANCE NO.: V-0001111/01-01-2014
Phone No: 09171234567
Email: attymocampo@yahoo.com

REQUEST FOR AND NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court
Pasig City, Metro Manila, Branch 68

Please submit the foregoing Motion to the Court for its

consideration and approval immediately upon receipt hereof and
kindly include the same in the Court’s calendar for hearing on March
10, 2018 at 8:30 in the morning.

ATTY. MARIZA R. OCAMPO

Counsel for the Plaintiff
Ocampo & Partners Law Offices
Ramos Bldg. Real St., Pasig City
Attys. Roll No. 12345/ 1-1-06
PTR No. 12345/1-03-17 Makati City, Metro Manila
IBP O.R. NO. 7654321/01-01-17, Manila Chapter
MCLE COMPLIANCE NO.: V-0001111/01-01-2014

Please take notice that counsel has requested to be heard on

March 10, 2018 at 8:30 in the morning.

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Copy furnished through personal service:

ATTY.
Counsel for defendant

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