Republic of the Philippines

[Region]
[COURT]
[City], [Branch No.]

[NAME]__________,
Plaintiff,
Civil Case No. ___________
- versus -

[NAME]__________,
Defendant.
x ----------------------------------- x

MOTION TO REOPEN THE TRIAL

Defendant, through the undersigned counsel and unto this Honorable

Court, respectfully avers:

1. That either/both parties have formally offered and closed their evidence;

2. That a judgment has not yet been rendered;

3. That a reopening of the trial for the reception of additional evidence is for
good reasons and in the furtherance of justice [EXPLAIN FURTHER WHY IT
IS FOR GOOD REASONS AND IN FURTHERANCE OF JUSTICE. SPECIFY THE
DETAILS.]

[CITY] ___________; [DATE] _________________________.

[SIGNATURE]
[NAME OF COUNSEL] ___________
Counsel for Plaintiff
[ADDRESS] ______________
IBP Lifetime No. ____________; [CITY] _____________
PTR No. _______________; [DATE], [CITY]
Roll of Attorney No. _______________________
MCLE Compliance No. ____________________

REQUEST FOR & NOTICE OF HEARING

THE BRANCH CLERK OF COURT

[COURT] ____________
[BRANCH] ____________, [CITY] __________________

Please submit the foregoing Motion to the Court for its consideration and
approval immediately upon receipt hereof and kindly include the same in the
courts calendar for hearing on Friday, [DATE] at [TIME] in the
[MORNING/AFTERNOON].

[NAME] _____________________
[ADDRESS] _____________________________

Please take notice that counsel has requested to be heard on Friday,

[DATE] at [TIME] in the [MORNING/AFTERNOON].
 [SIGNATURE]
[NAME] _________
Counsel for Plaintiff
[ADDRESS] ___________________

Copy furnished through personal service:

[NAME OF COUNSEL] __________________

Counsel for the Defendant
[FIRM NAME] _______________
[ADDRESS] ________________

[USE THE FOLLOWING IF SERVICE IS NOT MADE PERSONALLY]

Copy furnished through registered mail:

[NAME OF COUNSEL] __________________
Counsel for the Defendant
[FIRM NAME] _______________
[ADDRESS] ________________
Registry Receipt No. ________
Post Office ________________
Date _____________________

EXPLANATION

The foregoing [DESIGNATION OF PLEADING, MOTION, ETC]

_______________and its attachment were served on [NAME OF COUNSEL]
________________ by registered mail instead of personal service as counsel for
petitioner [STATE REASON] ___________________.

[SIGNATURE]
[NAME] _________________

Republic of the Philippines )

City of _______________ ) s.s.

AFFIDAVIT

I, [NAME] ____________ , a messenger of [NAME OF COUNSEL FOR

PLAINTIFF], with office address at [ADDRESS] __________________, after being duly
sworn, deposes and states:

That on [DATE] ______________________, I served a copy of the following

pleadings/papers by registered mail in accordance with Section 10, Rule 13 of the
Rules of Court:

Nature of Pleading/Paper
[STATE PLEADING/PAPER SENT]
________________________

in Case No. [CASE NUMBER] _________________ entitled [TITLE OF CASE]

____________________ by depositing a copy in the post office in a sealed envelope,
plainly addressed to [NAME OF PARTY/ATTORNEY] _______________ at
_______________ with postage fully paid, as evidenced by Registry Receipt No.
_____________________ attached and with instructions to the post master to return
the mail to sender after ten (10) days if undelivered.

TO THE TRUTH OF THE FOREGOING, I have signed this Affidavit on [DATE]

________________, in the City of [CITY] _____________, Philippines.

[SIGNATURE]
[NAME] __________
Affiant

SUBSCRIBED AND SWORN TO before me in the City of _______________ on

this day of [MONTH AND YEAR]_________________, affiant exhibiting before me his
Government Issued ID no. _______________ issued on [DATE}__________________ at
[PLACE OF ISSUANCE]_____________________.

[SIGNATURE]
[NAME]_______
Notary Public

Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________

Doc. No.
Page No.
Book No.
Series of [YEAR] ___________.