(Motion to Declare Defendant in Default)

(CAPTION)

MOTION
(TO DECLARE DEFENDANT IN DEFAULT)

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

1. The records of the Honorable Court show that Defendant was served with copy of the

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

2. 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;

3. 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 _____________ 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.

_____________, Philippines, __Date__.

(COUNSEL)

(NOTICE OF HEARING)

(EXPLANATION)

COPY FURNISHED:

OPPOSING COUNSEL