REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT

CITY OF MANILA, BRANCH ______

Mr. B,

Plaintiff

Vs. Civil Case No. _____

Mr. A, For recovery of Possession and Damages

Defendant

x------------------------------------x

MOTION

Plaintiff, by counsel, states that:

1. Mr. B, Plaintiff, Filipino, of legal age, single and a resident of Malolos, Bulacan. Plaintiff is represented
by Atty. X with office address at Makati City;

2. Mr. A, Defendant, Filipino, of legal age, single and a resident of Lipa City, Batangas;

3. Mr. A leased the townhouse of Mr. B situated at No. 1 Esperanza Street, Paco, Manila;

4. The period of the lease is from January 15, 2021 to January 15, 2022 with a monthly rental amounting
to Twenty Five Thousand Pesos (P 25,000.00);

5. The contract of lease dated January 15, 2021 states, among others, that a default of payment of at
least one (1) month, Mr. B shall cause the termination of the contract and the lessee to leave the
premises within ten (10) days;

6. On December 2021, Mr. A failed to pay the stipulated amount.

7. Mr. B, after complying with all the formalities required by law, filed a case in court to recover the
possession of the leased premises.

8. After the case was filed and after trial, the court rendered a decision in favor of Mr. B and ordered Mr.
A to vacate the property within fifteen (15) days.

9. The decision also awarded to Mr. B the amount of Twenty Five Thousand Pesos (P 25,000.00) as
damages.

10. Mr. A, filed a motion for reconsideration seeking the court to have a second look of the decision.
11. Mr. A argument lies on the fact that, his inability to pay was caused by the financial difficulties
brought about by the pandemic and added that the decision was contrary to law and existing
jurisprudence.

12. (Provision of Law)

PRAYER

WHEREFORE, premises considered, plaintiff respectfully prays that:

1. The court takes note of this motion

2. The court renders judgement on the pleadings;

3. Other reliefs just and equitable are likewise prayed for.

(Date) Makati for Manila

(sgd)

Atty. X

Makati City

Contact No.

Email Address

Roll No.

IBP No.

PTR No.

MCLE Compliance No.

Copy furnished and Notice of Hearing:

Branch Clerk of Court

City of Manila

Branch ___

Greetings! Please be advised that this Motion is set for hearing on _____ at _____ am/pm.

(sgd)

Atty. X

Makati City

Contact No.
 Email Address

Roll No.

IBP No.

PTR No.

MCLE Compliance No.

EXPLANATION

A copy of this motion was filed and served by registered mail because of lack of manpower.

(sgd)

Atty. X

Makati City

Contact No.

Email Address

Roll No.

IBP No.

PTR No.

MCLE Compliance No.

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT

City of Manila, Branch 333

Mr. A,

Plaintiff, Civil Case No. _____

VS. For Collection of Sum of Money

Mr. B,

Defendant,

x--------------------------x

MOTION

Defendant, by counsel, states that:

1. Mr. A filed a case for collection of sum of money against Mr. B before the Regional Trial Court of
Manila.

2. After service of summons, Mr. B timely filed his answer prompting the court to issue an Order setting
the case for Pre-trial on February 14, 2019.

3. The court issued its Pre-trial Order dated February 14, 2019. As indicated in the Pre-Trial Order, the
following are the witnesses of Mr. A:

(a) Miss D, his account manager

(b) Mr. X, his collection agent and

(c) Mr. Z, his liason officer.

4. The court directed the parties to present the testimonies of their respective witnesses using a Judicial
Affidavit. The initial hearing for the presentation of plaintiff’s evidence was set on February 28, 2019.

5. During the hearing on February 28, 2019, Atty. XX moved for the cancellation of the hearing on the
ground that his witness, Miss D recently had her appendectomy surgery.

6. Also, he likewise manifested that on February 21, 2019, defendant received a copy of the Judicial
Affidavits of all the witnesses.

7. The Court reset the presentation to March 22, 2019.

8. On March 22, 2019, when the case was called for the initial presentation of plaintiff’s evidence, Atty.
XX, manifested that Miss D could not attend the hearing because of a previous commitment.
9. Provision of law

PRAYER

WHEREFORE, premises considered, defendant respectfully prays that:

1. Court takes note of this Motion;

2. Declare the Plaintiff in Default;

3. Other equitable reliefs prayed for.

(Date) Makati for Manila

(sgd.)

Atty. X

Address

Contact No.

Email Address

Roll No.

IBP No.

PTR No.

MCLE No.

Copy furnished to

And Notice of Hearing:

Branch of Clerk of Court

City of Manila

Branch 333

Greetings! Please be advised that this Motion is set for hearing on _____ at _____ am/pm.

(sgd.)

Atty. X

Address

Contact No.

Email Address

Roll No.
 IBP No.

PTR No.

MCLE No.

EXPLANATION

A copy of this motion was served to the plaintiff by registered mail due to lack of manpower.

(sgd.)

Atty. X

Address

Contact No.

Email Address

Roll No.

III.

REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

REGIONAL TRIAL COURT

CITY OF LIPA, BRANCH

Mr. A,

Plaintiff Civil Case No. 1234

VS. For nullification of sale of piece of land

Mr. B,

Defendant

x----------------------x

Plaintiff, by counsel, states that:

1. After the summons was served upon B, the latter filed his Answer in due time.

2. B alleged therein, among others that, at the time the property was sold to him by Mr. C, he knew
earlier it was sold to Mr. A.

3. (provision of law)

PRAYER
WHEREFORE, premises considered, the plaintiff respectfully prays that:

1. That this motion be granted;

2. That the sale be nullified;

3. Other just and equitable reliefs prayed for.

Copy furnished to

And Notice of Hearing:

Branch of Clerk of Court

City of Manila

Branch ____

Greetings! Please be advised that this Motion is set for hearing on _____ at _____ am/pm.

(sgd.)

Atty. X

Address

Contact No.

Email Address

Roll No.

IBP No.

PTR No.

MCLE No.

EXPLANATION

A copy of this motion was served to the plaintiff by registered mail due to lack of manpower.

(sgd.)

Atty. X

Address

Contact No.

Email Address

Roll No.

IV.
REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT

City of Makati, Branch ____

Insurance Company X,

Plaintiff, Civil Case No. _____

VS. For Interpleader

Miss B and Miss C,

Defendant

x-----------------------------------------------x

COMPLAINT

Plaintiff, through Counsel, states that:

1. Mr. A insured himself for a life insurance policy with a face value of One Million Pesos (P
1,000,000.00) with Insurance Company X, an insurance company with principle place of business at
Makati City

2. He designated his “wife” as his beneficiary.

3. When he died, Miss B, a resident of La Union Province filed her claim for the insurance proceeds.

4. On the other hand, Miss C, a resident of Batangas City likewise filed her insurance claim. Insurance
Company X sought your legal assistance to determine who between Miss B and Miss C the insurance
proceeds will be awarded.

PRAYER

WHEREFORE, premises considered, the plaintiff respectfully prays that:

1. The court issue an order directing the claimants to interplead and litigate their conflicting claims;

2. The plaintiff be granted appropriate relief.

(Date) City of Makati

(sgd.)

Atty. X

Address

Contact No.
 Email Address

Roll No.

VERIFICATION AGAINST FORUM SHOPPING

I, Mr. X of legal age, single, residing at Manila, respectfully states that:

(1) The allegation herein are true and correct based on my personal knowledge;

(2) This complaint is not filed to harass, or cause unnecessary delay;

(3) The factual obligations herein have evidentiary support;

(4) I have not filed any action or claim involving the same issues in any court;

(5) If I learn that the same is filed, I shall report the fact within five (5) calendar days therefrom.

IN WITNESS WHEREOF, I hereunto affixed my signature this (date) at Makati City.

(sgd.)

Atty. X

Address

Contact No.

Email Address

Roll No.

JURAT

SUBSCRIBED AND SWORN to before me this (Date) at (Place where signed) affiant, Mr. X, exhibiting to
me his (Identification Card with Details).

NOTARY PUBLIC

Doc No.

Page No.

Book No.

Series of ___