[Court]

[Region]
[COURT]
[City], [Branch No.]

[NAME]__________,
Plaintiff,
Civil Case No. ___________
- versus - For: Sum of Money

[NAME]__________,
Defendant.
x ----------------------------------- x

MOTION FOR JUDGMENT ON THE PLEADINGS

Plaintiiff, by counsel, respectfully states that:

1. On [DATE] _____________, plaintiff sued defendant for a sum of money in the

amount of [AMOUNT IN PESOS] ____________________.

2. In his Answer, [STATE MATERIAL ALLEGATIONS ADMITTED]

____________________________. The Answer admits the material allegations of the
Complaint and has not tendered any issue; consequently, a judgment on the pleadings may
be rendered.

WHEREFORE, plaintiff respectfully prays that a judgment on the pleadings be

rendered in his favor.

[CITY] ___________; [DATE] _________________________.

[SIGNATURE]
[NAME OF COUNSEL] ___________
Counsel for Plaintiff
[ADDRESS] ______________

REQUEST FOR & NOTICE OF HEARING

THE BRANCH CLERK OF COURT

[COURT] ____________
[BRANCH] ____________, [CITY] __________________

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 Friday, [DATE] at [TIME] in the [MORNING/AFTERNOON].

[NAME] _____________________
[ADDRESS] _____________________________

Please take notice that counsel has requested to be heard on Friday, [DATE] at
[TIME] in the [MORNING/AFTERNOON].

[SIGNATURE]
 [NAME] _________
Counsel for Plaintiff
[ADDRESS] ___________________

Copy furnished through personal service:

[NAME OF COUNSEL] __________________

Counsel for the Defendant
[FIRM NAME] _______________
[ADDRESS] ________________

[USE THE FOLLOWING IF SERVICE IS NOT MADE PERSONALLY]

Copy furnished through registered mail:

[NAME OF COUNSEL] __________________
Counsel for the Defendant
[FIRM NAME] _______________
[ADDRESS] ________________
Registry Receipt No. ________
Post Office ________________
Date _____________________

EXPLANATION

The foregoing [DESIGNATION OF PLEADING, MOTION, ETC] _______________and

its attachment were served on [NAME OF COUNSEL] ________________ by registered mail
instead of personal service as counsel for petitioner [STATE REASON]
___________________.

[SIGNATURE]
[NAME] _________________

Republic of the Philippines )

City of _______________ ) s.s.

AFFIDAVIT

I, [NAME] ____________ , a messenger of [NAME OF COUNSEL FOR PLAINTIFF],

with office address at [ADDRESS] __________________, after being duly sworn, deposes
and states:

That on [DATE] ______________________, I served a copy of the following

pleadings/papers by registered mail in accordance with Section 10, Rule 13 of the Rules of
Court:

Nature of Pleading/Paper
[STATE PLEADING/PAPER SENT]
________________________

in Case No. [CASE NUMBER] _________________ entitled [TITLE OF CASE]

____________________ by depositing a copy in the post office in a sealed envelope, plainly
addressed to [NAME OF PARTY/ATTORNEY] _______________ at _______________ with
postage fully paid, as evidenced by Registry Receipt No. _____________________ attached
and with instructions to the post master to return the mail to sender after ten (10) days if
undelivered.

TO THE TRUTH OF THE FOREGOING, I have signed this Affidavit on [DATE]

________________, in the City of [CITY] _____________, Philippines.

[SIGNATURE]
[NAME] __________
Affiant

SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day

of [MONTH AND YEAR]_________________, affiant exhibiting before me his Government
Issued ID no. _______________ issued on [DATE}__________________ at [PLACE OF
ISSUANCE]_____________________.

[SIGNATURE]
[NAME]_______
Notary Public

Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________

Doc. No.
Page No.
Book No.
Series of [YEAR] ___________.