REPUBLIC OF THE PHILIPPINES

11th Judicial Region

Regional Trial Court
Branch 34
Panabo City

RAUL J M. RAMOS
AND MATTHEW J M. RAMOS,
Plaintiffs,

Represented by:
JOY M. MELENCION, CIVIL CASE NO.
Mother Cc 26-2017
Support
-versus-

JERSON D. RAMOS,
JR.,
Defendant.
X---------------------------------x

MOTION TO DECLARE DEFENDANT IN DEFAULT

PLAINTIFF, by and thru the undersigned counsel, unto this

Honorable Court, most respectfully manifests THAT:

As per Sheriffs Return of Service dated July 11, 2017, the

defendant Jerson D. Ramos Jr. was served with a copy of the
summons with the attached complaint and annexes on July 10, 2017
and the defendant had until July 25, 2017 to file his responsive
pleading;

As of this writing, the defendant neither filed an answer nor any

responsive pleading within the reglamentary period.

Section 3, Rule 9 of the Rules of Court provides:

Section 3. Default; declaration ofIf the defending party fails

to answer within the time allowed therefor, the court shall, upon
motion of the claiming party with notice to the defending party,
and proof of such failure, declare the defending party in default.
Thereupon, the court shall proceed to render judgment granting
the claimant such relief as his pleading may warrant, unless the
court in its discretion requires the claimant to submit evidence.
Such reception of evidence may be delegated to the clerk of
court.
 PRAYER
WHEREFORE, in view of the foregoing, it is most respectfully
prayed of this Honorable Court, that the above-named defendant be
declared in default and that judgment be rendered granting the
plaintiffs, support and such other relief, just and equitable, prayed for
in their petition.

Panabo City, Davao del Norte, Philippines. November 6, 2017.

PUBLIC ATTORNEYS OFFICE

Panabo District Office
Hall of Justice, Panabo City
Davao del Norte

JOAHNA PAULA Q. DOMINGO

Public Attorney I
PTR No. 9195872; 07/04/2017
IBP O.R No. 006046
Roll No. 67043
Admitted to Bar May 2017

NOTICE OF HEARING

The Clerk of Court

Regional Trial Court
Branch 34, Panabo City

Jerson D. Ramos Jr.

Greetings!

Please take notice that the undersigned counsel submitted the

foregoing for the consideration of this Honorable Court on November
6, 2017 without prejudice to further appearance and oral arguments
which may be required by the court of the undersigned counsel.

JOAHNA PAULA Q. DOMINGO

Copy furnished:

Jerson D. Ramos Jr.

c/o Manolette Bakery Shop
Buhangin Branch
Milan, Buhangin, Davao City