Allan Villagonzalo

Republic of XYZ National Capital Judicial Region METROPOLITAN TRIAL COURT Branch XII (12) City of ABC MOTION FOR JUDGEMENT ON THE PLEADINGS (SAMPLE) BANK 123, Plaintiff, -versus-CIVIL CASE: 123456 CORPORATION QWE, Defendant. X---------------------------------------------------------------------------------------------------------------------------X Plaintiff, by Counsel, respectfully alleges that: 1. On July 16, 2019, plaintiff sued defendant for a sum of money in the amount of One Million in Philippine currency (Php 1,000,000); 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 the 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 judgement on the pleadings may be rendered. WHEREFORE, it is respectfully prayed for that this Honorable Court render a judgment on the pleadings. City of ABC, Republic of XYZ, July 19, 2019. ATTY. VX YZ Counsel for Plaintiff NOTICE OF HEARING BRANCH OF CLERK OF COURT MeTC Branch 12 City of ABC ATTY. AB CD Counsel for the Defendant 0987 Gamo Street. ZXC City Greetings! Please take notice that the undersigned counsel will submit the foregoing Motion to the Honorable Court on August 5, 2019 at 8:00 in the morning for its favorable consideration and approval. ATTY. VX YZ Copy furnished by registered mail: ATTY. AB CD Counsel for the Defendant 0987 Gamo Street ZXC City EXPLANATION Due to lack of messengerial services to effect personal service, a copy of the foregoing motion was sent to the defendant’s counsel through registered mail. ATTY. VX YZ