REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
City of Manila
Branch ______

For:

Metropolitan Trial Court

Quezon City
Branch 39

EMERALD VYNIL CORPORATION,

Plaintiff,
Civil Case No. 18-04736
- Versus –

DREAMMAKERS PHILS. CONST.

CO. INC,
Defendant.
X * * * * * * * X

EX-PARTE MOTION FOR ISSUANCE

OF ALIAS SUMMONS

COME NOW, the Plaintiff, in the above-entitled case and unto

this Honorable Court most respectfully avers:

1. That Plaintiff received the Process Serve’s Return dated

August of Summons, dated August 6, 2018;

2. That in said Return, the Summons was received but refused

to sign by one Mercy Costas who introduced herself as Accounting
Head of the Defendant;

3. That there was Improper Service of the Summons as the

same was Not served upon the proper officers of the plaintiff
authorized to receive summons on behalf of the Corporation
pursuant to Section 11, Rule 14 of the Rules of Court which provide:

Service upon domestic private juridical entity. —

When the defendant is a corporation, partnership or
association organized under the laws of the Philippines
with a juridical personality, service may be made on the
president, managing partner, general manager, corporate
secretary, treasurer, or in-house counsel.
 4. That there is a paramount need and necessity that an
Alias Summons be issued so that the same may be served and
effected upon the designated and proper corporate officers or
in-house counsel of the defendant in conformity with and as required
by the Rules of Court.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable

Court that an Alias Summons be issued and that the same be served
and effected upon the Proper Officers of Defendant pursuant to the
Rules of Court.

Other reliefs just and equitable under the premises are likewise
prayed for.

Quezon City, Philippines, November 27, 2018.

MARICEL R. MEDINA
Credit and Collection Head
And
Duly Authorized Representative
of Plaintiff:
EMERALD VYNIL CORPORATION
Oliveros Drive, Brgy. Apolonio Samson
1106 Balintawak, Quezon City

NOTICE

The Branch Clerk of Court

MTC, Branch _____
_________________________

Greetings

Please submit the foregoing Motion for the kind consideration

and approval of the Honorable Court, immediately upon receipt
hereof.

MARICEL R. MEDINA