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Motion For Substitution Catbagan

This document contains a Motion for Substitution of Plaintiff in a civil case. The motion requests that the son of the deceased plaintiff, Evelyn Catbagan, be allowed to substitute her as the plaintiff in the unlawful detainer case against the defendant, Jose Bartolay. The motion provides details on the death of the original plaintiff and requests that all court documents be addressed to the substituted plaintiff, Marker B. Catbagan. The attorney filing the motion, Melanie Obrique-Guevarra, explains that service was made through LBC due to lack of resources for personal delivery.

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100% found this document useful (2 votes)
3K views2 pages

Motion For Substitution Catbagan

This document contains a Motion for Substitution of Plaintiff in a civil case. The motion requests that the son of the deceased plaintiff, Evelyn Catbagan, be allowed to substitute her as the plaintiff in the unlawful detainer case against the defendant, Jose Bartolay. The motion provides details on the death of the original plaintiff and requests that all court documents be addressed to the substituted plaintiff, Marker B. Catbagan. The attorney filing the motion, Melanie Obrique-Guevarra, explains that service was made through LBC due to lack of resources for personal delivery.

Uploaded by

attymel
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as ODT, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


METROPOLITAN TRIAL COURT
City of Parañaque
Branch 88

EVELYN CATBAGAN,                       
         Plaintiff,
 
                               CIVIL CASE No. 2019-12
-versus-           FOR: Unlawful Detainer

JOSE BARTOLAY.
              Defendant.
x---------------------------------------------------x

MOTION FOR SUBSTITUTION OF


PLAINTIFF EVELYN CATBAGAN

Undersigned Attorney unto this Honorable Court most respectfully states that:

1. Plaintiff died last February 23, 2019. Attached herewith is a copy of his
Certificate of Death.

2. Thus, it is hereby prayed that her only son, MARKER B. CATBAGAN, be


allowed to substitute her as PLAINTIFF in this case.

3. It is prayed that all summons, orders and processes of the court be sent and
addressed to MARKER B. CATBAGAN at 356/1503 (B) Parejo St.,Sto. Niño De
Culdesac, Sun Valley, Parañaque City.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that this Motion for


Substitution be granted.

Other reliefs, just and equitable under the premises are likewise prayed for.

Paranaque City, March 20, 2019.

COS GUEVARRA
& ASSOCIATES LAW OFFICES
Counsel for the Plaintiff
Unit 210 Doña Eusebia Rodriguez Bldg.,
0611 Quirino Ave., san Dionisio, Parañaque City
Tel. No.825-99-18/ 09989984009
By:

ATTY. MELANIE OBRIQUE-GUEVARRA


PTR NO. 1741150 – 1/ 17/2019, PARANAQUE CITY
IBP NO. 070285 – 1/21/2019, PASIG CITY
Roll No.56511
MCLE COMPLIANCE NO. VI-0014042

EXPLANATION

Pursuant to Rule 13, Section 11 in relation to Section 6 of the 1997 Rules of Civil
Procedure, the service and filing of the foregoing Motion for Substitution of Plaintiff
was made to the counsel of defendant through LBC due to the lack of personnel and
sufficient resources to effect service and filing by personal delivery.

ATTY. MELANIE OBRIQUE-GUEVARRA

NOTICE OF HEARING:

Clerk of Court
MTC-Branch 88
Paranaque City

TABAQUERO ALBANO LOPEZ & ASSOCIATES


Atty. Benedicto D. Tabaquero
3rd Floor, Unit K, #854 Sta. Catalina Street,
San Antonio Valley 1, Parañaque City
Metro Manila

Please submit this motion for the consideration of the Honorable Court without
need for further hearing in view of the above circumstances.

ATTY. MELANIE OBRIQUE-GUEVARRA

Copy furnished:

TABAQUERO ALBANO LOPEZ & ASSOCIATES


Atty. Benedicto D. Tabaquero
3rd Floor, Unit K, #854 Sta. Catalina Street,
San Antonio Valley 1, Parañaque City
Metro Manila

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