1.(b)

Republic of the PhilippinesREGIONAL TRIAL COURTNATIONAL CAPITAL Judicial RegionMetro manilaBranch 30

ALEXANDER SISON Plaintiff, Civil Case No: 1234- versus -FOR:Collection of Sum of Money With DamagesJUAN JAMERO, Defendant.x - - - - - - - - - - - - - - - - - - x

MOTION TO DECLARE THE DEFENDANT IN DEFAULTCOMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable court, most avers:1.That the summons in the above-entitled case was duly served on March 15, 2015 to the Defendant;

2. That notwithstanding the lapse of more than fifteen (15) days, defendant failed to file his answer or responsive pleading;

3. Therefore, it is respectfully prayed that Defendant be declared in default pursuant to Section 3, Rule 9 of the Rules of Court and that the Honorable Court proceed to render judgment as the complaint may warrant.

PRAYER

WHEREFORE, premises considered, it is most respetfully prayed f this Honorable Court that the defendant be declared in default, and the plaintiff be allowed to present his evidence ex-parte.

Other reliefs and remedies as may be deemed just and equitable under the premises are likewise prayed for.City of Manila, Philippines, March 31, 2015.

ATTY. LAURENCE SUSAN P. ORTIZ Counsel for the Plaintiff Ortiz Law Office, Sampaloc, Manila PTR No. 22334, 01/17/14, Manila City IBP No. 44556, 01/10/14, Manila City Roll of Attorney No. 44661 MCLE Compliance No. VI-010489

NOTICE OF HEARING

THE CLERK OF COURT Branch 30Regional Trial Court, Metro ManilaSir/MadameG R E E T I N G S:Please submit the foregoing motion for the consideration and approval of the Honorable Court immediately upon receipt hereof.

ATTY. LAURENCE SUSAN P. ORTIZ Counsel for the Plaintiff Ortiz Law Office, Sampaloc, Manila PTR No. 22334, 01/17/14, Manila City IBP No. 44556, 01/10/14, Manila City Roll of Attorney No. 44661 MCLE Compliance No. VI-010489

COPY FURNISHED:BY PERSONAL SERVICE

ATTY. DAVE ROBERT C. CAPADACounsel for the PlaintiffGerochi Law Office, Sampaloc, ManilaReceived April 2, 2015