Demand Letter for collection of sum

of money Please be reminded that I have sent you

several letters of demand for you to pay
12 August 2013 your back rentals and to vacate the
premises but the same letters have been
MARIA C. SANTOS left unanswered. Consider this then, as
111 Bonifacio Street, Canumay East, my last and final demand for you to pay
Valenzuela City your account within five (5) days from
receipt and to VACATE the premises
within ten (10) days from receipt of this
notice. Otherwise, I shall be constrained
Madam:
to commence suit to protect my interests.
We write in behalf of our
client, ABCD Financial Services, Inc., the Very truly yours,
matter of your non-payment of your
obligation.
Motion for Extension of Time to File
Records disclose that you have an Answer Responsive Pleading
outstanding obligation with our client in
the amount of Php100,000.00 inclusive (CAPTION)
of interest and surcharges. Despite
repeated demands, you failed and MOTION FOR EXTENSION OF TIME
continuously fail to pay the aforesaid
amount.  DEFENDANT, by the undersigned counsel,
and unto this Honorable Court, most
Accordingly, FINAL DEMAND is hereby respectfully states that:
made upon you to settle the amount
of Php100,000.00 within FIFTEEN 1. Defendant engaged the services of
(15) days from receipt of this letter. undersigned counsel only on _____________;
Otherwise, we will be constrained
to file the necessary legal action against 2. Defendant was served with Summons
you to protect the interest of our client.  and copy of the Complaint on _____________
and thus has until _____________ within
We trust that you will give this matter which to submit an Answer or Responsive
Pleading;
your prompt and preferential attention
to avoid the expense and inconvenience
3. However, due to the pressures of
of litigation.
equally urgent professional work and
prior commitments, the undersigned
Truly yours, counsel will not be able to meet the said
deadline;
ATTY. JUAN C. DELA CRUZ
4. As such, undersigned counsel is
constrained to request for an additional
Demand Letter to Vacate and Pay period of _____________ from today within
which to submit Defendant's Answer or
Date __________ Responsive Pleading. Moreover, this
additional time will also allow the
Name of respondent undersigned to interview the available
Address witness and study this case further;

Dear Mr./Mrs/Ms _________ 5. This Motion is not intended for delay

but solely due to the foregoing reasons.
It has been 30 days since you received my
letter dated ______ and still, you have failed PRAYER
to pay and still refuses to pay your
arrears which have now amounted to WHEREFORE, Defendant most
NINETY ONE THOUSAND PESOS (P respectfully prays of this Honorable Court
91,000.00) . that he be given an additional period of
_____________ from today within which to those persons named or enumerated in
submit an Answer or other Responsive Section 11, Rule 14 of the 1997 Rules of
Pleading. Civil Procedure upon whom service of
summons shall be made;
Other relief just and equitable are
likewise prayed for. The material provision on the service of
summons provided for in Section 11 of
_____________, Philippines, __Date__. Rule 14 of the 1997 Rules of Civil
Procedure reads as follows:
(COUNSEL)
"Section 11. Service upon domestic
(NOTICE OF HEARING) private juridical entity.- When the
defendant is a corporation, partnership or
(EXPLANATION) association organized under the laws of
the Philippines with a juridical
COPY FURNISHED: personality, service may be made on the
president, managing partner, general
OPPOSING COUNSEL manager, corporate secretary, treasurer,
or in-house counsel" (underscoring ours)

Motion to Dismiss It bears no further emphasis that the

service of the summons was done on a
(CAPTION) person who is not included in the
exclusive enumeration provided for
MOTION TO DISMISS under the said Section, as service was
done only on an alleged authorized
COMES NOW the Respondent, _____________ personnel of the Movant Corporation;
Inc., through the undersigned counsel,
appearing especially and solely for this This new revision of the Rules of Court for
purpose, and to this Honorable Court, the service of summon is a clear
most respectfully moves for the dismissal departure from the old rule as stated in
of the Complaint on the following ground Section 13, Rule 14 of the Rules of Court
that THE HONORABLE COURT HAS NOT which provided that:
ACQUIRED JURISDICTION OVER THE
PERSON OF THE DEFENDING PARTY. "SECTION 13.Service upon private
domestic corporation or partnership. - If
DISCUSSION the defendant is a corporation organized
under the laws of the Philippines or a
A cursory reading of the Summons and partnership duly registered, service may
Return of Service would readily show that be made on the president, manager,
the copies of the Summons dated 08 May secretary, cashier, agent, or any of its
2001 and the Complaint and its directors."
corresponding annexes were allegedly
delivered and tendered upon the Movant It must be equally noted that the changes
_____________ INC. through a certain Maria in the new rules are substantial and not
Clara alleged to be the authorized just general semantics as the new rules
personnel of Movant _____________ INC., restricted the service of summons on
Bacolod City on 29 August 2001. Copies of persons clearly enumerated therein. In
the said Summons and Return of Service effect, the new provision makes it more
that form part of the records on the case specific and clear such that in the case of
are hereto pleaded as integral part of this the word "manager", it was made more
Motion; precise and changed to "general
manager", "secretary" to "corporate
Said service of Summons, however, secretary", and excluding therefrom agent
constitutes an improper service of and director;
summons amounting to lack of
jurisdiction over the person of the herein The designation of persons or officers
Movant Corporation _____________ INC. who are authorized to accept summons
since the summons was improperly for a domestic corporation or partnership
served upon a person who is not one of is under the new rules, limited and more
clearly specified, departure from which is render judgment as the complaint may
fatal to the validity of the service of the warrant.
summons and resulting in the failure of PRAYER
the court to acquire jurisdiction over the
person of the respondent corporation. WHEREFORE, it is respectfully prayed
that Defendant _____________ be declared in
PRAYER default pursuant to the Rules of Court and
that the Honorable Court proceed to
WHEREFORE, it is respectfully prayed render judgment as the complaint may
that the Complaint with respect to the warrant.
Movant Corporation be dismissed for lack
of jurisdiction over the person of the Other relief just and equitable are
defendant. likewise prayed for.

Other reliefs just and equitable are _____________, Philippines, __Date__.

likewise prayed for.
(COUNSEL)
_____________, Philippines, __Date__.
(NOTICE OF HEARING)
(COUNSEL)
(EXPLANATION)
(NOTICE OF HEARING)
COPY FURNISHED:
(EXPLANATION)
OPPOSING COUNSEL
COPY FURNISHED:

OPPOSING COUNSEL

Motion to Declare Defendant in Default

(CAPTION)

MOTION

(TO DECLARE DEFENDANT IN

DEFAULT)

Plaintiff, by counsel and unto this

Honorable Court, respectfully states

1.The records of the Honorable Court

show that Defendant was served with
copy of the summons and of the
complaint, together with annexes thereto
on _____________;

2.Upon verification however, the records

show that Defendant _____________ has
failed to file his Answer within the
reglementary period specified by the
Rules of Court despite the service of the
summons and the complaint;

3.As such, it is respectfully prayed that

Defendant _____________ be declared in
default pursuant to the Rules of Court and
that the Honorable Court proceed to