REPUBLIC OF THE PHILIPPINES

___ Judicial Region

MUNICIPAL TRIAL COURT IN CITIES
BRANCH __,
___ City

MARIA ELENA CLARA

Plaintiff

CIVIL CASE NO.

______________
-versus-
FOR: Actual, Moral,
Exemplary damages,
Litigation and Attorney’s
fees

CRISOSTOMO IBARRA
Defendant.
x-------------------------------------------------------x

MOTION TO ARCHIVE

Comes now plaintiff thru the undersigned Counsel, unto this

Honorable Court, most respectfully avers that:

1. Plaintiff filed this complaint in the above-entitled case on

February 5, 2018;

2. That per process server return dated February 13, 2018 issued
by this Honorable Court, Summons was returned unserved for the reason
that the defendant is not a resident of the given address. Further, an Alias
Summons was issued and likewise it was returned unserved for the reason
that the defendant allegedly went abroad;

3. So as not to leave this case pending before the dockets of this

Honorable Court, it is to the best interest of the plaintiff that this instant case
be ARCHIVED momentarily subject to revival at the latter date when
defendant returns in her residence from her overseas employment.

PRAYER

WHEREFORE, premises considered, counsel of the plaintiff most

respectfully pray unto this Honorable Court that this case be ARCHIVED
momentarily.

1
 Other reliefs, just and equitable under the premises are likewise
prayed for.

07 September 2018. Cebu City, Philippines.

By:

CASSANDRA MONDRAGON
Counsel of the plaintiff
Roll No. 14344
IBP no. AR5348/11-29-17/______ City
PTR no. 1427354/12-11-17/ _____ City
MCLE Compliance no: V-837393003