COMES NOW the plaintiff, by the undersigned counsel, and unto this Honorable Court, respectfully alleges:

      1. That the defendant, in his answer, admits the material allegations of the plaintiff's complaint;

      2. That said admission which fails to tender an issue, refers to the following matters, to wit:________________;

      3. That a judgment on the pleadings, in view of the above admissions, may be entered at this stage of the proceedings.

      WHEREFORE, it is respectfully prayed that this Honorable Court direct judgment on the pleadings pursuant to Rule 19 of the Rules of Court.

      Cebu City, _________________, 2004.