Republic of the Philippines

REGIONAL TRIAL COURT

11th JUDICIAL REGION
Branch 55
Davao City

JOSELITO CALEM MANOLOTO Civil Case No. 25653-098

Plaintiff FOR: Sum of Money
-vs-

ROSA ROSAS,
Defendant.

x-----------------------------------------x

MOTION FOR JUDGMENT ON THE PLEADINGS

Plaintiiff, by counsel, respectfully states that:

1. On 5 December 2020, plaintiff sued defendant for a sum of

money in the amount of FIVE HUNDRED THOUSAND PESOS (P
500,000.00)

2. The Answer admits the material allegations of the Complaint

and has not tendered any issue; consequently, a judgment on the
pleadings may be rendered.

WHEREFORE, plaintiff respectfully prays that a judgment on the

pleadings be rendered in his favor.

City of Davao, February 28, 2020.

NENARIA LAW FIRM

8th floor, ABC Bldg., Ecoland, Davao City
Tel Nos. [082] 555-8888;
E-mail address: janinenenaria31@gmail.com

By:

ATTY. JANINE LOUISE MAE E. NENARIA

 Counsel for Plaintiff
Notary Public for Davao
Notarial Commission No. 2019-09
Until December 31, 2019
Rm. 597 ABC Building, Davao City
Roll No. 7987
PTR No. 59781198/ 2-14-23
IBP Lifetime Member 1993
MCLE No. 0091812-08-09-93
 NOTICE OF HEARING

The Branch Clerk of Court

Regional Trial Court
Branch 55, Davao City

Greetings!

Please submit the foregoing motion to the Court for its

consideration and approval immediately upon receipt hereof and kindly
include the same in the court’s calendar for hearing on April 12, 2020 at
8:30 in the morning.

(SGD) ATTY. JANINE LOUISE MAE E. NENARIA

COUNSEL FOR THE PLAINTIFF

Atty. Queenie Reyes

Counsel for the Defendant
No. 88 Lemon Town, Davao City

Please take notice that counsel has requested to be heard on April

12, 2020 at 8:30in the morning.

(SGD) ATTY. JANINE LOUISE MAE E. NENARIA

COUNSEL FOR THE PLAINTIFF

EXPLANATION AS TO SERVICE

Copy of this Motion to Dismiss was served the counsel for plaintiff
thru registered mail. Personal service cannot be effected due to lack of
manpower, as well as distance and time constraints

ATTY. JANINE LOUISE MAE E. NENARIA

Copy Furnished:
Atty. Queenie Reyes
Counsel for the Defendant
QR LAW OFFICES
Room 5 ABC Building, Ecoland, Davao City