Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

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. ___________________________________

Counsel for Plaintiff

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

RTC - Branch 39

Quezon City

Greetings!

Kindly submit the foregoing motion for consideration and approval of this Honorable Court immediately upon receipt hereof.

___________________________________

Copy furnished by registered mail:

ATTY. AB CD

Counsel for the Defendant

2233 Zamora Street, Pasay City

Please take notice that counsel has requested for the approval of this motion immediately upon receipt.

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