Motion For Judgment On The Pleadings

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Republic of the Philippines

National Capital Judicial Region


METROPOLITAN TRIAL COURT
Branch LXII (62)
Makati City

STERLING BANK OF ASIA,


Plaintiff,

- versus
- Civil Case No.111222

ELLA CORPUZ MAPA,


Defendant.
x-------------------------------------------x

MOTION FOR JUDGMENT ON THE PLEADINGS

Plaintiff, by counsel, respectfully alleges that:

1. On May 5, 2013, plaintiff sued defendant for a sum of money in the amount of
Two Hundred Thousand Pesos (P200,000.00);

2. In his Answer, defendant admitted the obligation and merely stated that he
was asking to be given an extension of time to pay his obligation, but that
plaintiff instead filed the Complaint;

3. Said Answer has not tendered any issue and in fact it can be read therefrom
that defendant admitted the obligation; consequently, a judgment on the
pleadings may be rendered.

WHEREFORE, it is respectfully prayed that this Honorable Court render


a judgment on the pleadings.

Makati City, Philippines. August 5, 2013.

ATTY. VX YZ
Counsel for Plaintiff
NOTICE OF HEARING

THE BRANCH CLERK OF COURT


MeTC - Branch 62
Makati City

ATTY. AB CD
Counsel for the Defendant
1234 Zamora Street, Pasay City

Greetings!

Please take notice that the undersigned counsel will submit the foregoing
Motion to the Honorable Court on August 27, 2013 at 8:30 in the morning for
its favorable consideration and approval.

ATTY. VX YZ
Counsel for Plaintiff

Copy furnished by registered mail:

ATTY. AB CD
Counsel for the Defendant
2233 Zamora Street, Pasay City

EXPLANATION

Due to lack of messengerial services to effect personal service, a copy


of the foregoing motion was sent to defendant's counsel through registered
mail.

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