Motion to Render Judgment- Sample

REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION METROPOLITAN TRIAL COURT

BRANCH ______, _______________________ _______________________

 _______________________,  _______________________, Plaintiff, CIVIL CASE NO. ____ For: COLLECTION OF SUM OF MONEY

 _______________________  _______________________ Defendant.  x---------------- x-----------------------------------------------------------------x ---x MOTION TO RENDER JUDGMENT

Plaintiff thru counsel to this Honorable Court, most respectfully states that: 1. On  _______________   _______________ , Plaintiff filed the above-entitled case against Defendant with the Honorable Court, paying the appropriate docket fees. 2. Summons and a copy of the complaint was finally served unto the defendant on _______________________, thru defendant’s daughter,  _______________________,  _______________________, a person of suitable age and dscretion. (Pls. see attached Summons  and Sheriff ’s ’s Return of Summons, Annexes “A” and “B” , respectively). 3. On _______________________ , plaintiff’s counsel inquired with the office of this Honorable Court as to whether or not defendant have already filed his Answer within the period prescribed by Rules. Plaintiff’s counsel was then told by the person in-charge in-charge of civil cases that there is yet no Answer filed. 4. The reglementary period to answer has expired without the defendant filing any answer. 5. For this reason, a judgment may now be rendered by this Honorable Court motu proprio   or upon motion of the Plaintiff, as may be warranted by the facts alleged in the Complaint and limited to what is prayed for therein.

WHEREFORE, premises considered, it is respectfully prayed for that judgment be rendered in favor of Plaintiff and against the Defendant, ordering the Defendant to pay Plaintiff: a. The amount of _______________________, representing defendant’s indebtedness with legal interest from the date of final demand; b.

The amount of _______________________as Attorney's Fees plus Appearance Fee at the rate of  _______________________per court hearing; c.

The costs of suit.

Other reliefs just and equitable under the premises are also prayed for. RESPECTFULLY SUBMITTED. Las Piñas City, _______________________

 _______________________  Counsel for the Plaintiff MCLE No. _______________________; ____________ PTR No. ____________; Cavite; ____________ IBP No. ____________; ____________  ____________________________________  ____________, Las Piñas City Email: ________________________ Contact No.: ________________________

 THE CLERK OF COURT Metropolitan Trial Court Las Piñas City G R E E T I N G S: Please take notice that on ____________ at 1:30 o’clock in the afternoon or soon thereafter as counsel and matter may be heard, the undersigned counsel will move the Honorable Court

to grant the foregoing motion without further argument and appearance.  ________________________  Copy Furnished:  ____________  ________________________ EXPLANATION

Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure, Due to lack of material time and absence of a messenger to cause the personal service of this pleading, undersigned counsel was constrained to serve a copy of the same by registered mail to the defendant.

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