MOTION FOR SUPPORT PENDENTE LITE (2001)

Question No. 16:

Draft a motion for support pendente lite to be filed in your client’s pending case in the Regional Trial
Court of Pasay City.

Answer:
REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 1, Pasay City

WIFE,
Plaintiff,

- versus - Civil Case No. 0001011

HUSBAND,
Defendant.
x ----------------------------------------------- x

Plaintiff through counsel, respectfully states that:

1. On 01 June 2001, plaintiff filed the complaint in the above case praying, among others, that defendant be
ordered to give plaintiff a monthly support.
2. As alleged in the complaint, defendant and plaintiff are husband and wife, having been legally married on 08
December 1996 at the Our Lady of Sorrows Church, Pasay City. A certified true copy of their marriage contract
is hereto attached a Annex “A”, hereof.
3. As also alleged in the complaint, defendant has abandoned the conjugal home on 24 January 1998 without
justifiable cause or reason, and since then defendant has failed to give any support to the plaintiff.
4. The plaintiff is without any source of income as shown by her affidavit attached hereto as Annex “B” hereof,
whereas the defendant is a medical doctor actively engaged in the practice of his profession with an average
monthly income of P80,000.00 more or less.
5. Considering the present prices of essential commodities, plaintiff needs a monthly allowance and support of
P15,000.00 for her sustenance during the pendency of the instant case.

WHEREFORE, it is most respectfully prayed of this Honorable Court that the defendant be ordered to give the
plaintiff a monthly support pendente lite of P15,000.00 to be paid at plaintiffs residence on or before the 10 th day of
each month.

Place, Date.

Atty. D
Counsel for Plaintiff
Roll of Attorneys No. _____
PTR No. ______; [date issued][place issued]
IBP No. ______; [date issued][Chapter]

(Notice of Hearing)
Atty. A
Counsel for Plaintiff
(Address)
Sir:
Please take note that on ______________, 2001 at ____ a.m., the undersigned counsel will submit the
foregoing motion to the Honorable Court for its consideration and resolution.

Atty. D
ENTRY OF APPEARANCE (2002)
Question No. 12:
Jose Malinlang is accused of estafa upon complaint of Joyce Mapagbigay. The case is pending before the
Regional Trial Court, Branch 1, Manila, where it is docketed as Criminal Case No. 5430. Joyce engages your
services as a private prosecutor. File your formal entry of appearance. For purposes of this pleading, your name is
Pedro Cruz.

Answer:

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 7, Manila

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - Criminal Case No. 102078

JOSE MALINLANG, For: ESTAFA

Accused.
x ----------------------------------------------- x

The Clerk of Court

Regional Trial Court
Branch 7, Manila

Kindly enter the appearance of the undersigned as Private Prosecutor in the above-entitled case, under the
supervision and control of the Public Prosecutor, with the conformity of the complainant Joyce Mapagbigay, as shown
below.

Accordingly, it is respectfully prayed that the undersigned be furnished copies of all pleadings, orders, and
notices relative to the instant case at its address indicated below.

Manila, Philippines, September 22, 2005.

PEDRO CRUZ
Counsel for the Complainant
Address: _________________

CONFORME:

JOYCE MAPAGBIGAY
Complainant

Copies Furnished by personal delivery:

The City Prosecutor

Manila

Atty.____________________
Counsel of the Accused
(address)
MOTION TO DISMISS (2002)
Question No. 14:
Prepare a motion to dismiss an action for a sum of money in the RTC Branch 1, Quezon City on the ground
of improper venue. Supply the other hypothetical facts and use Pedro Cruz as your name.

Answer:

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 1, Quezon City

JUAN DE LA CRUZ,
Plaintiff,

- versus - Civil Case No. 102078

PEDRO PATERNO, For: Sum of Money Defendant.

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

MOTION TO DISMISS

NOW COMES Defendant, by his undersigned attorney, and to this Honorable Court respectfully moves that the
complaint be dismissed on the ground that VENUE HAS BEEN IMPROPERLY LAID.

ARGUMENT

The Rules of Court provides that a complaint in a civil case cognizable by the Regional Trial Court should be
filed in the RTC of the place where the plaintiff or the defendant resides, at the option of the plaintiff. The complaint
in the above-entitled case expressly alleges that the plaintiff is a resident of Makati City while the defendant is a
resident of Caloocan City. Hence, venue has been improperly laid.

PRAYER

WHEREFORE, it is respectfully prayed that the complaint be dismissed.

Quezon City, Philippines, September 16, 2002.

PEDRO CRUZ
(Attorney for Defendant)
__________________________
(Address)

Roll of Attorneys No. _____

PTR No. ______; [date issued][place issued]
IBP No. ______; [date issued][Chapter]

Atty. Purisima (By personal service)

Counsel for the Plaintiff
(address)

Madame:
Please be notified that on October 11, 2002 at 8:30 a.m. or as soon thereafter as the matter may be heard, the
undersigned counsel will submit the foregoing motion to the Honorable Court for its consideration and resolution.
PEDRO CRUZ