Republic of the Philippines

Third Judicial Region

MUNICIPAL TRIAL COURT IN CITIES
CITY OF MALOLOS
Province of Bulacan
Branch II

PASENSYA UBOSNA,
Plaintiff,

- versus - CIVIL CASE NOS. 16-237

KAPAL MUKS,
Defendant.
x-------------------x

MOTION FOR RECONSIDERATION

PLAINTIFF, through the undersigned Public Attorney, unto

this Honorable Court, most respectfully states:

1. That Plaintiff issued a demand letter on 18 February 2017 for the

Defendant to pay unpaid rental obligations and vacate the
property located at #143 Laging Nag-aaway Street, Di Mapayapa,
Malolos, Bulacan ;

2. That the lease contract between the plaintiff and the defendant
states that it shall be valid only for two (2) years. Hence, the lease
contract expired on 30 January 2016, and the Plaintiff decided not
to extend the said contract.

3. That Plaintiff respectfully sent a demand letter to the defendant

for him to pay the outstanding unpaid rental obligation in the
amount of Five Hundred Thousand Pesos (Php500,000.00)
representing the unpaid five months and to vacate the premises
thereof.

4. That on 01 March 2017, the court ruled in favor of the Defendant,

allowing the Defendant to stay to our property, despite the clear
and definite intention of the demand letter that we sent.

5. That Plaintiff respectfully moves for the reconsideration of the

aforesaid Orders.
 PRAYER

WHEREFORE, premises considered, it most respectfully prayed unto

this Honorable Court that an Order be issued reinstating the direct
testimony and the bond of the accused and lifting the warrant of arrest
issued against the Accused.

Other reliefs as are just and equitable under the premises form part of
this prayer.
MOST RESPECTFULLY SUBMITTED this 11th day of March 2017
in Malolos City, Bulacan.

Department of Justice
PUBLIC ATTORNEY’S OFFICE
Malolos City District
2 Floor, Hall of Justice Bldg.,
nd

Provincial Capitol Compound

Malolos City, Bulacan
Tel No. (044) 305-0370
By:

MA. ALYANNA C. OLAGUER

Public Attorney II
Roll No. 64822
IBP Lifetime No. 02488 (04/ 15/ 2014)
MCLE Compliance No. V-001963; 4-15-15

NOTICE

MS. DIAN MARIE HAS

Clerk of Court
MTC, Branch 2
Malolos City, Bulacan

Greetings:
Kindly submit the foregoing Motion for the consideration and
approval of the Honorable Court immediately upon receipt hereof.

MA. ALYANNA C. OLAGUER