CLIENT’S COPY

Republic of the Philippines

National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 147
City of Makati

LUZ R. MANIPON, NOEMI R.

CHICO, and THELMA R. RA-
MOS represented by LYN-
DON R. RAMOS,
Plaintiffs,

-versus- Civil Case No. 15-754

For: Partition

ELEONOR RAMO LUCAS and

CESAR RAMO
Defendants.
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MOTION TO ADMIT
[Attached Answer to the Complaint dated 29 July 2015]

Defendant ELEONOR RAMO LUCAS, through counsel, and

unto this Honorable Court most respectfully seeks the admission
of the attached Answer to Complaint dated 29 July 2015, and in
support thereof, states that:

1.0 On 03 September 2015, Eleonor received a summons

from this Honorable Court requiring her to file an Answer within
fifteen (15) days after service or until 18 September 2015.
However, due to financial constraint, Defendant was not able to
timely secure the services of counsel to represent her in the
instant case.

1.1 It was only on September 30, 2015, when the services

of the undersigned counsel was engaged. Forthwith, this
representation carefully evaluated the Complaint and all
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MOTION TO ADMIT ATTACHED ANSWER

related documents necessary to draft an intelligent Answer.

However, it, still, took him more than three (3) days to complete
this Answer.

1.2 While a defendant is required to file an Answer to the

Complaint within fifteen (15) days after service of summons,1 the
court may allow an answer or other pleading to be filed after the
time fixed by these Rules.2

1.3 Additionally, the court may allow the admission of an

Answer belatedly filed when it is due to the following: [1]
excusable negligence; [2] the defendant has meritorious
defenses; [3] it was filed before defendant is declared in default;
and [4] that the late filing of the answer did not in any way
prejudice or deprive the plaintiff of any substantial right, nor was
there intention to unduly delay the case.3

1.4 Eleonor, through counsel, is filing this Motion to Admit

attached Answer based on the foregoing grounds and in the
interest of substantial justice.

ACCORDINGLY, it is respectfully prayed of this Honorable

Court to grant this Motion and issue an order admitting the
attached Answer.

OTHER RELIEFS just and equitable under the foregoing

premises are likewise prayed for.

[Explanation: Copies of this Motion have been served on

the counsel for the Plaintiffs and on the Honorable Court by
registered mail in view of the distance involved and lack of
messenger who could undertake personal service.]

City of San Pedro, Laguna for Makati City, 05 October 2015

1 Section 1, Rule 11, Rules of Court

2 Section 11, Id.
3 Sps. Delos Santos vs. Hon. Carpio and Metrobank, G.R. No. 153656, September 11, 2006

citing Mercader vs. Hon. Bonto, G.R. No. L-48564, August 20, 1979
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MOTION TO ADMIT ATTACHED ANSWER

[Attorney’s Box]

[NOTICE OF HEARING]