REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
MARIKINA, BRANCH 1

Mr. A,
PLAINTIFF, CIVIL CASE NO. 12345
-versus- FOR: Collection of Sum of
Money
Mr. B,
DEFENDANT.
X--------------------------------------X

MOTION

Plaintiff, by counsel, states that:

1. Plaintiff on (DATE) filed this present case against defendant.
2. On (DATE), summons was properly served upon defendant.
3. Defendant has until (last day that the defendant must file responsive
pleading) to file his responsive pleading.
4. Up to present, no responsive pleading was filed.
5. (Provision of law/jurisprudence)

PRAYER/RELIEF
Plaintiff prays that:
1. The Court takes note of this motion.
2. Declare defendant in default.
3. Allow plaintiff to present evidence ex parte on a date most convenient to
the Court.
Other equitable reliefs are likewise prayed for.
(Date), Quezon City for Marikina.
(signed)
Atty. F
Roll No. __
 IBP No. __
PTR No. __
MCLE Compliance No. __
Notice of Hearing and
Copy furnished to:

The Branch Clerk of Court

Regional Trial Court of Marikina, Branch 1
(ADDRESS)

Mr. B
(ADDRESS)
OR (if counsel is known)
Atty. E
(ADDRESS)

Greetings!
Please take note that the undersigned shall submit this motion for the
consideration of this Court on (DATE)(TIME).
(SIGNED)
Atty. F
EXPLANATION
A copy of this motion was filed and served by registered mail because of lack
of manpower.
(SIGNED)
Atty. F
 REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
MARIKNA, BRANCH __

Mr. A
PLAINTIFF, Civil Case No. __
-versus- For: Collection of Sum of Money
Mr. B
DEFENDANT.
X----------------------------------------X

COMPLAINT
Plaintiff, by counsel, states that:
1. Mr. A (Plaintiff) is a Filipino, of legal age, a resident of (ADDRESS). He may
be served with the orders of the and processes of this Court at the address
of his counsel indicated below.
2. Mr. B (Defendant) is also a Filipino, of legal age and a resident of
(ADDRESS).
3. On (SPECIFIED DATE), defendant borrowed from the plaintiff the sum of
Three Million Pesos (P 3, 000, 000.00) for the expansion of his business.
4. The loan is evidence by a Contract of Loan dated (DATE) and further
secured by a Promissory Note No. ___ dated (DATE).

Copies of the aforementioned Contract of Loan and Promissory Note are

attached as Annexes “A” and “B” respectively.

5. The Contract of Loan states among others that the loan is payable in 4
monthly installments beginning (DATE) with an interest of (INTEREST
RATE) per annum as stated under paragraph (PARAGRAPH NUMBER IN THE
CONTRACT).
6. On (DATE), Mr. C, the collection agent of the plaintiff sent an Office
Memorandum stating that defendant did not make any payment since
(DATE).

Copy of the aforementioned memorandum is attached as Annex “C”.

7. Mr. C as the collection agent can testify in Court that indeed the defendant
failed to pay the loan as agreed upon under the Contract of Loan.

A copy of Judicial Affidavit of Mr. C is attached as Annex “D”.

8. Prompted by the said Memorandum, plaintiff directed Mr. C to prepare a

Demand Letter demanding the full payment of the loan and interest within
fifteen (15) days from the receipt of the said demand letter.

A copy of the Demand Letter is attached as Annex “E”.

9. On (DATE), Mr. D, the liaison officer of plaintiff personally served to the

defendant the Demand Letter.
10.Mr. D can testify in Court that he personally served upon the defendant a
copy of the Demand Letter and that defendant received the same.

A copy of the Judicial Affidavit of Mr. D is attached as Annex “F”

11.Despite receipt of the Demand Letter, no payment was made.

12.(PROVISION OF LAW/JURISPRUDENCE)

PRAYER/RELIEF

Plaintiff respectfully prays that:

1. Order the defendant to pay the amount of the loan in the amount of
Three Million Pesos and the stipulated interest.
Other equitable reliefs are likewise prayed for.
(DATE), Quezon City for Marikina.

(SIGNED)
Atty. F
Roll No. __
IBP No. __
PTR No. __
MCLE Compliance No. __

VERIFICATION AND CERTIFICATION AGAINT FORUM SHOPPING

I, Mr. A, of legal age, Filipino, and a resident of (ADDRESS), under oath
hereby depose and state that:
1. The allegations herein are true and correct to the best of my personal
knowledge or based on authentic documents.
2. This complaint is not filed to harass, cause unnecessary delay, or
needlessly increase the cost of the litigation.
3. The factual allegations herein have evidentiary support or, if
specifically so identified, will likewise have evidentiary support after
reasonable opportunity of discovery.
4. I hereby certify that I have not commenced any action or filed any
claim involving the same issues in any court, tribunal or quasi-judicial
agency and, to the best of my knowledge, no such other action or
claim is pending therein.
5. If I should thereafter learn that the same or similar action or claim has
been filed or is pending, I shall report that fact within five (5) calendar
days therefrom.

(DATE), Quezon City for Marikina.

(SIGNED)
Mr. A
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, this (DATE) day of (MONTH)

(YEAR), in the City of (CITY WHERE EXECUTED), affiant exhibiting to me
his (IDENTIFICATION NO AND VALIDITY) issued by the (AGENCY WHO
ISSUE THE ID) on (DATE OF ISSUANCE OF THE ID), at the (CITY WHERE
ISSUED).

(SIGNED)
Atty. F
Notary Public
Commission Valid Until (DATE)
Roll No. __
IBP No. __
PTR No. __
MCLE Compliance No. __
Doc No. __
Page No. __
Book No. __
Series of __