Republic of the Philippines

Third Judicial Region

MUNICIPAL TRIAL COURT OF BULAKAN
Province of Bulacan

Luisito Dela Cruz

Plaintiff

For: Collection of Sum of Money Damages

and Attorney’s Fees
Civil Case No. 1339
Versus

Annaliza Reyes Javier

Defendant
x--------------------------x

MOTION TO DECLARE DEFENDANT IN DEFAULT

Plaintiff, by counsel and unto this Honorable Court, respectfully states:

1. On ________, the complaint, in this case, was filed by the Plaintiff;

2. The records of the Honorable Court show that Defendant was served

with a copy of the summons and of the complaint, together with
annexes thereto on _____________;

3. Upon verification however, the records show that Defendant 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;

4. As such, it is respectfully prayed that Defendant 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 Annaliza Reyes Javier

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

Other relief just and equitable are likewise prayed for.

Bulakan, July 26, 2022

ATTY. ARACELI B. GLORIA

Counsel for the Plaintiff
c/o Gloria Law Office
044-305-8905; 0950-654-9858
3049 Bambang Bulacan Bulacan
Roll Number 69656
IBP Number 197844 January 6, 2022
PTR 8222800 January 5, 2022
MCLE No. VI-0030286 until April 14, 2022
atty.araceligloria@gmail.com
+63917-555-0367

Copy furnished:

Annaliza Reyes Javier