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    Motion To Declare in Default

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    Caroline Lugay
    This document is a motion filed in a civil case in the Regional Trial Court of Bogo City, Cebu, Philippines. The motion requests that three defendants - Sps. Ricardo Ancajas and Ma. Delisa Lepon, Georgina Dy Tugonon, and Mariles Dy Ang - be declared in default for failing to file an answer to the complaint within the required period, despite being properly served. The motion provides details on the service and summons of the defendants, and requests that the court proceed to render judgment as warranted by the complaint.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Motion To Declare in Default

    Uploaded by

    Caroline Lugay
    49 views3 pages
    This document is a motion filed in a civil case in the Regional Trial Court of Bogo City, Cebu, Philippines. The motion requests that three defendants - Sps. Ricardo Ancajas and Ma. Delisa Lepon, Georgina Dy Tugonon, and Mariles Dy Ang - be declared in default for failing to file an answer to the complaint within the required period, despite being properly served. The motion provides details on the service and summons of the defendants, and requests that the court proceed to render judgment as warranted by the complaint.

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    Motion to Declare in Default

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    This document is a motion filed in a civil case in the Regional Trial Court of Bogo City, Cebu, Philippines. The motion requests that three defendants - Sps. Ricardo Ancajas and Ma. Delisa Lepon, Georgina Dy Tugonon, and Mariles Dy Ang - be declared in default for failing to file an answer to the complaint within the required period, despite being properly served. The motion provides details on the service and summons of the defendants, and requests that the court proceed to render judgment as warranted by the complaint.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    49 views3 pages

    Motion To Declare in Default

    Uploaded by

    Caroline Lugay
    This document is a motion filed in a civil case in the Regional Trial Court of Bogo City, Cebu, Philippines. The motion requests that three defendants - Sps. Ricardo Ancajas and Ma. Delisa Lepon, Georgina Dy Tugonon, and Mariles Dy Ang - be declared in default for failing to file an answer to the complaint within the required period, despite being properly served. The motion provides details on the service and summons of the defendants, and requests that the court proceed to render judgment as warranted by the complaint.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 3

    Republic of the Philippines

    REGIONAL TRIAL COURT


    7th Judicial Region
    BRANCH 79
    Marcelo B. Fernan Palace of Justice
    Dakit, Bogo City, Cebu

    JOVITO U. ATON, LUCIA CIVIL CASE NO. BOGO-03973


    ALEGRE LEVA, NOEL For: EASEMENT OF RIGHT OF
    METANTE PEVIDA, and MA. WAY, APPLICATION FOR
    JANET GUEVARRA, PRELIMINARY INJUNCTION
    Plaintiffs, WITH PRAYER FOR
    TEMPORARY RESTRAINING
    - versus – ORDER
    SPS. LAZARO ORTEGA and
    VICTORIA ABALLE,
    LAMBERTO PELAYO, VICTOR
    ORTEGA, JOSE EMBERT D.
    CATARATA, SPS. RICARDO
    ANCAJAS and MA. DELISA
    LEPON, MILDRED DY
    ECHAVEZ, GEORGINA DY
    TUGONON, and MARILES DY
    ANG,
    Defendants.
    x------------------------------------------
    ----/

    MOTION TO DECLARE DEFENDANTS IN DEFAULT

    COMES NOW, the plaintiffs, through the undersigned counsel and


    unto this Honorable Court, most respectfully avers:

    1. The records of the Honorable Court show that Defendant SPS.


    RICARDO ANCAJAS and MA. DELISA LEPON were served
    personally with the summons together with a copy of the complaint on
    June 29, 2021;

    2. Summons by publication were made to Defendants GEORGINA DY


    TUGONON and MARILES DY ANG on May 22, 2022 in Banat News
    pursuant to an Order made by this Honorable Court on January 2022.
    They were directed to file their Answers to the Complaint within sixty
    (60) days after the date of publication;

    3. Upon verification however, the records show that Defendants SPS.


    RICARDO ANCAJAS and MA. DELISA LEPON, GEORGINA DY
    TUGONON, and MARILES DY ANG have failed to file their ANSWER
    Page 1 of 3
    within the reglementary period specified by the Rules despite the service
    of the summons and the complaint.

    4. As such, it is respectfully prayed that Defendants SPS. RICARDO


    ANCAJAS and MA. DELISA LEPON, GEORGINA DY TUGONON,
    and MARILES DY ANG be declared in default pursuant to the Rules of
    Court and that the Honorable Court proceed to render judgment as the
    complaint may warrant.

    5. Plaintiffs hereby submits a copy of the Affidavit of Publication executed


    by the Editor in Chief of Banat News as Annex "A" and a copy of the
    newspaper clipping as Annex "B.

    PRAYER

    WHEREFORE, it is respectfully prayed that Defendants SPS.


    RICARDO ANCAJAS and MA. DELISA LEPON, GEORGINA DY
    TUGONON, and MARILES DY ANG be declared in default pursuant to the
    Rules of Court and that the Honorable Court proceed to render judgment as
    the complaint may warrant.

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

    RESPECTFULLY SUBMITTED.

    March 1, 2023, Bogo City, Cebu, Philippines.

    RHETT VINCENT M. MINGUEZ


    Counsel for the Plaintiffs
    Room 101, Northomes Pensione
    Pelaez St., Sto. Niño, Bogo City, Cebu
    0917-626-0668 | minguezlaw@gmail.com
    Roll of Attorneys No. 72614
    MCLE Compliance No. VII - 0009262 | 4/14/2025
    IBP OR No. 240704 | 11/28/2022 | Pasig City
    PTR No. 1493504 | 01/03/2023 | Bogo City

    REQUEST
    Page 2 of 3
    ATTY. JULIE B. MACAPOBRE-DELOS REYES
    The Branch Clerk of Court
    RTC Branch 79, Bogo City

    GREETINGS:

    Please submit the foregoing motion for consideration and resolution at


    any time convenient for the Honorable Court.

    Thank you.

    ATTY. RHETT VINCENT M. MINGUEZ

    NOTICE, SERVICE OF COPY AND EXPLANATION

    Copy furnished to:

    ATTY. FROILAN QUIJANO JR.


    Zosa and Quijano Law Offices
    Don Mariano Cui St., Cebu City
    Registry Receipt No.
    Dated:

    ATTY. REY P. ECHAVEZ


    28. P. del Rosario Ext., Cebu City

    Greetings!

    Please be notified that the undersigned will submit the foregoing


    motion for consideration and resolution at any time convenient for the
    Honorable Court with or without the appearance of the undersigned counsel.

    Copies of this motion were served to Atty. Quijano and Atty.


    Echavez by registered mail due to distance and lack of personnel to effect
    personal service thereof.

    ATTY. RHETT VINCENT M. MINGUEZ

    Page 3 of 3

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