Legal Forms 2009

ON WRITING, LEGALLY
(2009 Revision)1
THEODORE O. TE2
Intended for Exclusive Use of the University of the Philippines College of Law
Bar Examination Candidates for 2009 in the Professional Enhancement Program-Bar Review 2009
Any other use, without permission of the author, is prohibited and all legal rights are reserved.
These forms were first made in 1997 and distributed n 1998 for use in the UP-LSG Bar Ops for that year; its
was formerly titled Pleadings, Petitions, Motions and Other Legal and Judicial Forms. It was last revised in
this form 2007; the contents are also published by CDAsia as Philippine Legal and Judicial Forms and
copyright is owned by the Author. All rights are reserved..
2
Assistant Professor, University of the Philippines; Vice President for Legal Affairs, University of the
Philippines; Former Director, Office of Legal Aid; Ll.B., U.P. (1990); Grateful acknowledgement is given to
Atty. Feliz Marie M. Guerrero, J.D. U.P. (2008) for invaluable assistance in re-formatting, proofreading and
updating of legal references.
TABLE OF CONTENTS
Table of Contents
On Writing, Legally
I.
COMMON FORMS
A. Caption and Title
B. Prayer
C. Jurat
D. Verification
E. Certification against Forum Shopping
F. Combined Verification and Certification against Forum Shopping
G. Combined Verification, Certification against Forum Shopping, and
Statement of Material Dates
H. Request for and Notice of Hearing
I. Proof of Personal Service
J. Proof of service by registered mail (with Explanation for failure to serve
personally)
K. Place, date, signature, address, Roll number, IBP receipt number, PTR
number
L. Acknowledgement
M. Notice of Appeal
II.
PLEADINGS AND OTHER LEGAL DOCUMENTS IN CIVIL PROCEDURE

A. Complaint (and other initiatory pleadings)
1. Complaint for ejectment with damages
2. Complaint for sum of money
3. Complaint for Replevin
4. Complaint to set period of years for lease
B. Answer with affirmative defenses and counterclaims
1. Answer with compulsory counterclaim
2. Answer with counterclaim and cross-claim
C. Pre-trial Brief
D. Motions
1. Motion to Dismiss (with Request for and Notice of Hearing)
2. Motion for leave of court to file pleading (with explanation for service
by registered mail)
3. Motion for Judgment on the Pleadings
4. Ex parte motion to set for trial
5. Motion for postponement
6. Motion for extension of time
7. Motion to declare defendant in default
8. Motion to lift order in default
E. Special Civil Actions
1. Certiorari (with Injunction and/or TRO), Prohibition and Mandamus
a. Certiorari
b. Prohibition
c. Mandamus
2. Quo warranto, Interpleader, Quieting of Title, and Declaratory Relief
a. Complaint in Interpleader
ii
ii
v
1
1
1
2
2
2
3
3
3
4
4
5
5
6
7
8
9
10
12
13
15
16
17
18
19
20
21
22
23
24
25
26
b. Action to Quiet (or Remove Cloud on) Title

c. Action for Declaratory Relief
d. Quo Warranto
III.
IV.
V.
VI.
PLEADINGS AND OTHER LEGAL FORMS IN CRIMINAL PROCEDURE

A. Complaint-Affidavit and Counter-Affidavit
1. Complaint-Affidavit
2. Counter-Affidavit
B. Information and Complaint
1. Information (with Certificate of Preliminary Investigation or Inquest)
a. Bigamy
b. Theft
c. Attempted Rape
d. Frustrated Murder
C. Motions
1. Motion to Quash Information
2. Motion to Quash Search Warrant
3. Motion to Suppress Evidence
4. Motion for Bail
D. Application for Bail
PLEADINGS AND OTHER LEGAL DOCUMENTS COMMON TO CIVIL AND
CRIMINAL PROCEDURE
A. Offer of Evidence and Opposition/Comment to Offer
1. Formal Offer of Evidence
2. Comment/Opposition to Offer
B. Demurrer to the Evidence
1. Criminal cases
2. Civil cases
C. Notice of Lis Pendens
D. Appearance as Counsel
E. Withdrawal as Counsel
1. Withdrawal with conformity of client
2. Withdrawal without conformity of client
F. Substitution of Counsel
G. Notice of Appeal
PLEADINGS AND LEGAL DOCUMENTS ON DOMESTIC CASES AND SPECIAL
PROCEEDINGS
A. Petition for Habeas Corpus
B. Petition for Adoption
C. Petition for Declaration of Nullity of Marriage with Application for
Provisional Orders
D. Petition for Probate of Holographic Will
DEEDS, CONTRACTS AND OTHER CORPORATE LEGAL DOCUMENTS
A. Special Power of Attorney
B. General Power of Attorney
C. Contract of Lease
iii
27
28
29
30
31
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
48
49
49
50
51
52
54
55
55
56
D.
E.
F.
G.
H.
I.
J.
K.
L.
M.
N.
O.
P.
Q.
R.
S.
VII.
Holographic Will
Notarial Will
Attestation Clause for a Notarial Will
Acknowledgement of a Notarial Will
Donation Inter Vivos
Acknowledgment of Nominee Status with Assignment of Shares
Secretarys Certificate
Board Resolutions
1. Authority to Act
2. Increase in number of directors and necessary amendment to the
Articles of Incorporation
Deed of Assignment
Deed of Sale of Registered Land (unilateral)
Deed of Sale of Unregistered Land (unilateral)
Deed of Sale with Pacto de Retro (bilateral)
Deed of Repurchase of land sold under Pacto de Retro
Deed of Sale with Mortgage
Dacion en Pago (Deed of Assignment of Real Estate in payment of debt)
Chattel Mortgage
APPEALS AND OTHER RESORTS TO APPELLATE COURTS IN CRIMINAL AND

CIVIL PROCEDURE
A. Ordinary Appeals
1. in civil cases
a. from MTC (in original jurisdiction) to RTC (in appellate jurisdiction)
b. from RTC (in original jurisdiction) to CA
2. in criminal cases
a. from MTC (as trial court) to RTC (in appellate jurisdiction)
b. from RTC (as trial court) to CA
c. from RTC (as trial court) to SC
B. Petitions for Review
1. from RTC (as appellate court) or from quasi-judicial agencies to CA
2. from RTC (on pure questions of law) or CA (in appellate jurisdiction) to
SC
VIII. FORMS RELEVANT TO THE WRITS OF AMPARO AND HABEAS DATA

A. Amparo
B. Habeas Data
iv
57
57
58
58
59
60
61
61
61
62
63
64
65
66
67
68
69
70
70
70
70
70
70
71
71
ON WRITING, LEGALLY
Therefore, its name was called Babel,
because there the Lord confused the
language of all the earth. Genesis, 11:9,
ESV
If brevity is the soul of wit, what now is to become of lawyers (and law students) who
would nonchalantly write a 100-page document and dare call it a Brief?
The traditional notion of legal writing is that it is a competition to put together as
many four to five-syllable words in a one-paragraph sentence. The language of the law
mystifies and with this comes the power of the lawyer for the more obscure and obtuse3 the
language, the greater the need for a lawyer.
History has given us many language handicaps and obstacles to clarity and precision.
Throughout four or five years of law school, the law student, who eventually becomes a
lawyer, is trained to think in archaic words and phraseslegalesewhich appear to have great
legal significance but are actually too imprecise to help anyone understand what is going on.
And to add to the Babelish situation, there are hundreds of words in a dead languageLatin
that have little relevance to the contemporary world.
There is a sea change, however, going on in legal writing. More and more, pleaders
are asked to be clear and concise, precise not pedantic. Why waste five words when only
three will do?4 But change, as always, is difficult and painful. Yet, it is an essential response
to todays evolving legal profession. Indeed, when the most common means now of
communicating is faster than sound SMS, with its own subculture and lingo, there must be a
re-examination of the archaic and pedantic manner by which legal writing presents itself.
What this short introduction to the accompanying handbook of Pleadings, Petitions,
Motions and Other Legal and Judicial Forms seeks to do is to put forth the need to write
clearly and concisely, precisely but not pedantically. What this Forms book seeks to do is to
assist the fledgling5 and seasoned legal pleader, drafter and advocate by presenting in the
form they are required to appear, with words that are clear and concise, precise not pedantic.
When a judges attention span is short and his reading backlog is long, the need to
write concisely, clearly, precisely and not pedantically becomes absolutely urgent.
Writing concisely and not pedantically, however, does not mean that the legal writer
ought to cut corners when it comes to substance as well as form; the only thing that that
guarantees is a baleful stare and a rude dismissal from the judge. Not only must the writer
The use of the word is deliberate and intended to be ironic--to demonstrate the point.
My favorite, and many of my students will attest to this, is the absolutely archaic Comes Now, the Plaintiff,
by the undersigned counsel, unto this Honorable Court, respectfully states thatas part of every pleading. Why
waste 15 words, when 6 will do, thus: Plaintiff, by counsel, respectfully states that. The latter loses none of
the legal gravitas but loses every bit of the archaic pretense that mystifies the law and perpetuates the notion that
laywers know what they are doing each and every time.
5
It was originally intended as a bar examination guide and as a teaching tool for evidence and procedure
classes.
4
know the arguments and the bases for his arguments, but she must also realize that these
arguments need to be presented in a manner that is technically sufficient.
It is hoped that the forms presented here, with checklists6 of legal requirements and
short annotations, will provide the impetus for demystifying legal writing and legal drafting.
These forms come from actual forms used in the authors practice, some from worthy
opponents and still some from traditional form books, with updates to fit the current state of
the Rules.
While this handbook was produced, primarily, with bar examinees and the law intern
or law student in mind, it is hoped that it might prove helpful as well when September ends7
and life, as a lawyer, begins in earnest.
Theodore O. Te
3rd Floor, Quezon Hall (Southwing),
University of the Philippines, Diliman, Quezon City
6
Acknowledgment is given to Atty. Alex M. Enriquez, (Ll.B., UP, 1990) for the original template of the
Checklists, which have been updated to suit current practice.
7
The reference is to the song by Green Day, an American punk band, entitled Wake Me Up When September
Ends, which has absolutely nothing to do with the bar or taking the bar (as it refers to a death in the family)
except the month referred to in the title and the yearning expressed to see the month end. It has, at some point
in time, aptly become an unofficial anthem of sorts for some bar examinees, Much more apt perhaps than My
Way which starts with, And now the end is near.
vi
ti l
it l J icil i
I L IL
r c , il
3. the docket number, if assigned (Sec. 1,

par. 1, Rule 7, ROC).
____________________,

li tiff,
ivil s ._______________
r _______________________
-vrs s-
Comment [G2]: The TITLE indicates the

names of the parties, who shall be named
in the original complaint or petition.
However, in subsequent pleadings, it shall
be sufficient if the name of the 1st party on
each side be stated with an appropriate
indication when there are other parties.
Their respective participation in the case
shall be indicated (Sec. 1, par. 2 &3, Rule
7, ROC).
______________________,

f t.
x------------------x
. Pryr
PRAYER
EREFORE it is rsctflly ry, ft r tic ri, t t t ft rr t

y t litiff t t f One illin Pess (Php. ,,) fr ctl nd cpenstry damages,

Fifty housand Pesos

damages, Fifty housand Pesos (Php. ,
) for exemplary

(Php. , ) for moral
) for attorneys fees.
damages, and Fifty housand Pesos (Php. ,
Other just and equitable reliefs are also prayed for.
. Jurt
SUBSCRIBED AND SWORN O before me in the City of _______________ on this day of

_________________, affiant exhibiting before me his overnment Issued ID no. _______________
issued on __________________ at _____________________.
(Sgd.) N. O. ARIO
Notary Public
Until __________________
PTR No. _______________
Issued at ______________
On ___________________
Doc. No.
Page No.
Book No.
Series of .
Comment [G3]: The JURAT accompanies

any notarized document that is declaratory
in nature, as opposed to a notarized
document that transmits rights or
property, which must be accompanied by
an ACKNOWLEDGMENT.
Note that if the document is subscribed
before a public officer duly authorized to
take oaths, then there is no need for the
affiant to produce a CTC nor for the entry
into a Notarial Register; thus, the italicized
portion of the JURAT is dispensed with but
not the oath itself.
Comment [4]: The use of Community

Tax Certificates is now discouraged as it is
far too easy to obtain and highly difficult to
authenticate. Instead what is now required
to be stated is government issued
identification or GIID (e.g., Drivers lic ense,
SSS/GSIS Identification etc.)
Comment [G5]: JURAT refers to an act in
which an individual, on a single occasion:
1. appears in person before a notary public
(NP) and presents an instrument or
document
2. is personally known to the NP or
identified by the NP through competent
evidence of identity as defined by these
Rules
3. signs the instrument or document in the
presence of the NP
4. takes an oath or affirmation before the
NP as to such instrument or document
(Sec. 5, 2004 Rules on Notarial Practice,
A.M. No. 02-8-13-SC effective August 1,
2004).
Republic of the Philippines

City of _______________
C.
.
.
.
)
) s.s.
(Sec. 4, par. 2, Rule 7, ROC).
. ilfiger, after having been duly s orn in accordance ith law, deposes and states that:
e is the plaintiff in the pleading/document entitled (pleading/document being verified)
e has caused its preparation
e has read it and the allegations therein are true and correct of his own knowledge or
based on authentic records.
Under Sec. 4, par.3, Rule 7, a verification

based on information and belief or upon
knowledge, information and belief is
considered defective and the pleading
unverified/unsigned.
Comment [G7]: 1994 and 2004 Bar

Exams
(Sgd.) C. . ILFIER
PLUS: Jurat
: Pleadings required to be verified

. All pleadings under the Rules of Summary Procedure
. Complaints for
a. Forcible entry
b. Unlawful detainer
c. Replevin
. Complaints with application for injunction or attachment
. Answer to complaint or counterclaim based on actionable documents
. Petitions for
a. Certiorari
b. Prohibition
c. andamus
d. abeas Corpus
e. Change of Name
. Certifition ginst orum Shopping

CERTIFICATION AGAINST FORUM SHOPPING
City of _______________
)
) s.s.
C. . Hilfiger, after having been duly sworn in accordance with law deposes and states that:
. He is the plaintiff in the case entitled (title of the case);
. He certifies that he has not commenced any action or filed any claim involving the same
issues before any other court, tribunal or quasi-judicial agency;
. To the best of his knowledge, there is no such pending action or claim;
. If he should learn that
a similar action or claim has been filed or is pending he shall report
such fact within five ( ) days from the discovery to this Honorable Court.
(Sgd.) C.. HILFIGER
PLUS: Jurat
. Combined Verifi tion nd Certifition ginst orum Shopping

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING
I, C.. Hilfiger, of legal age, do hereby state that: I am the Chief Executive Office of Alis Di-yan
Company and in such capacity, caused this Complaint to be prepared; I have read its contents and affirm
that they are true and correct to the best of my own personal knowledge; I hereby certify that there is no
other case commenced or pending before any court involving the same parties and the same issue and
that, should I learn of such a case, I shall notify the court within five () days from my notice.
IN WITNESS WHEREOF, I have signed this instrument on _____________.
PLUS: Jurat
(Sgd.) C.. HILFIGER
Comment [G8]: Under Rule 7, Sec. 5, the

plaintiff or principal party must certify
under oath in the complaint, initiatory
pleading, or sworn certification that:
1.he has not commenced any action or filed
any claim involving the same issues in any
court, tribunal or quasi-judicial agency
and, to the best of his knowledge, no such
other action or claim is pending there
2. if there is such other pending action or
claim, a complete statement of its present
status, and
3. if he should thereafter learn that the
same or similar action or claim has been
filed or is pending, he shall report that fact
within 5 days to the court where his
complaint or pleading was filed.
Failure to comply with this reqt is not
curable by mere amendment but shall be
cause for dismissal w/o prejudice, UNLESS
otherwise provided, upon motion and after
hearing.
Submission of a false certification or noncompliance with its undertakings shall
constitute indirect contempt of court, w/o
prejudice to corresponding admin and crim
actions.
Comment [G9]: 2004 Bar Exams
I, C.. Hilfiger, of legal age, do hereby state that: I am the Chief Executive Office of Alis Di-yan
Company and in such capacity, caused this Complaint to be prepared; I have received a copy of the
[Order/Resolution/Decision] of the Court on April ; I have read its contents and affirm that they
are true and correct to the best of my own personal knowledge; I hereby certify that there is no other
case commenced or pending before any court involving the same parties and the same issue and that,
should I learn of such a case, I shall notify the court within five () days from my notice.
IN WITNESS WHEREOF, I have signed this instrument on _____________.
(Sgd.) C.. HILFIGER
PLUS: Jurat
H. equest for nd oti e of hearing

REQUEST FOR & NOTICE OF HEARING
THE BRANCH CLERK OF COURT
Metropolitan Trial Court
Quezon City, Branch

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, April
at q: in the morning.
ATTICUS FINCH
MockingBird Street
Timog Avenue, Quezon City
Please take notice that counsel has requested to be heard on Friday, April at q: in the
morning.
(Sgd.) MITCH MCDEERE
Counsel
for Defendant
The Firm
Laguna Street, Quezon City
I.
Proof of personal servi e
Copy furnished through personal service:

Atty. Mitch McDeere
sCounsel for the Defendant
The Firm
Comment [tG10]: NOTE: The Notice of

Hearing is actually both a REQUEST and a
NOTICE; a REQUEST for the Branch Clerk
of Court to include the motion in the
calendar for hearing on a specific date and
a NOTICE to opposing counsel of the
hearing date requested. In non-litigious
motions or ex parte motions, it is sufficient
that the request not contain a date, and for
that purpose, the underlined portion in the
Request may be omitted with the Notice to
opposing counsel simply stating that
counsel will submit the motion to the
court for approval immediately upon
receipt.
Atty. Mitch McDeere
Counsel for the Defendant
The Firm
Registry Receipt No. ________
Post Office ________________
Date _____________________
EXPLANATION
The foregoing (designation of pleading, motion, etc.) and its attachment were served on Atty.
Mitch McDeere by registered mail instead of personal service as counsel for petitioner only has one
messenger and personal service would have resulted in the motion not being filed on time to the
detriment of petitioner.
(Sgd.) ATTICUS FINCH
City of _______________
Comment [G11]: The requirement is for a

written explanation if service is done by
registered mail instead of by personal
service; the explanation need not be
verified, it being required only that it is
signed. However, in the Supreme Court,
where an Affidavit of Service is required, it
may be practical to combine the
Explanation and the Affidavit of Service. Cf.
Rule 13, sections 11 and 13.
)
) s.s.
AFFIDAVIT
I, HARPER LEE, a messenger of Atty. Atticus Finch, with office address at __________________,
after being duly sworn, deposes and states:
That on ______________________, I served a copy of the following pleadings/papers by
registered mail in accordance with Section , Rule of the Rules of Court:

Nature of Pleading/Paper
________________________
________________________
in Case No. _________________ entitled ____________________ by depositing a copy in the post office
in a sealed envelope, plainly addressed to (name of party or his/her 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 ( ) days if undelivered.
TO THE TRUTH OF THE FOREGOING, I have signed this Affidavit on April

Manila, Philippines.
, in the City of
(Sgd.) HARPER LEE

Affiant
PLUS: Jurat
. Place, date, signature, address, oll number, I P receipt number, PTR number,
CLE Compliance or Exemption umber, Contact Details
City of Manila, April

.
Atty. Mitch McDeere
Counsel for the Defendant
The Firm, Laguna Street,
Quezon City, Metro Manila
(Telephone, Fax, mail)
Roll No.
IBP OR No., date and place of issue
PTR OR No., date and place of issue
MCL Compliance/xemption No.
Comment [LR12]: As per A.M. NO. 07-6-5SC, counsels are now required to indicate
in their pleadings or other legal documents
their contact details aside from address,
i.e., telephone, fax, mobile or email
address.
Comment [G13]: As per SC En Banc
Resolution on Bar Matter No. 1132 dated
Nov. 12, 2002, all pleadings must indicate
the ff:
1. Roll of Attorneys number of counsel
2. Current Professional Tax Receipt
number (PTR No.)
3. IBP Official Receipt or Life Member
number
Comment [LR14]: As per BM 1922, MCLE
compliance or exemption number for the
specific compliance period must be stated;
failure to do so may mean dismissal of the
case or expunction of the pleading. (Note:
this came as a result of Justice Nachuras
letter to the SC noting the diminished
interest in the MCLE)
BEFORE ME, this th day of April, in the City of Manila, Philippines, personally appeared
ATTICUS FINCH, with [Valid Identification Document] (Drivers License No. N25--) issued by the
[official agency] (Land Transportation Office) on January 2007, known to me to be the same person
who executed the foregoing instrument, and who acknowledged to me that the same is his free act and
deed.
IN WITNESS WHEREOF, I have set my hand and affixed my Notarial seal on the day, year and
place written.
(Sgd.) N. O. TARIO
Notary Public
Until __________________
PTR No. _______________
Issued at ______________
On ___________________
Doc. No.
Page No.
Book No.
Series of 2007
TE: If the instrument consists of 2 or more pages, include the following after the st paragraph:
This instrument, consisting of ___ pages, including the page on which this acknowledgment is
written, has been signed on the left margin of each and every page thereof by ___________ and his
witnesses (if any), and sealed with my Notarial seal.
TE: If the instrument conveys 2 or more parcels of land, include the following after the st paragraph:
This instrument relates to the sale (or mortgage) of ___ parcels of land, and consists of ___
pages including the page on which this acknowledgment is written, each and every page of which, on the
left margin, having been signed by ______________ and his witnesses (if any), and sealed with my
Notarial seal.
. otice of ppeal
NOTICE OF APPEAL
Defendant, ABC, by counsel, respectfully appeals to this Honorable Court the Decision of the
lower court dated April 2007, a copy of which he received on 26 April 2007.
Quezon City, 2 May 2007.
Counsel for Defendant
2 The Firm
Comment [G16]: The Notary Publics seal

must be impressed on every page of the
document notarized.
[1] Regional Trial Court

National Capital Judicial Region
METROPOLITAN TRIAL COURT
Quezon City, Branch

ALIS DI-YAN COMPANY,
Plaintiff,
Civil Case No. 2222
For: Ejectment
- versus -
4. Statement of Cause(s) of Action

5. Prayer/Reliefs
6. Date/Place of Execution
7. Signature of Counsel
8. Verification and Certification Against
Forum Shopping
Comment [G18]: 1976, 1982, 1985,

1988, 1993, 1994, 1996, 1997 and 2000
Bar Question
YOKO NGA,
Defendant.
x -----------------------------------x
COMPLAINT
PLAINTIFF, by counsel, respectfully states that:
[2] . Plaintiff is a foreign corporation organized and existing under the laws of France with
business address at Ocean Drive, Tuna Compound, Quezon City; Defendant is a Filipino, of legal age,
single and currently resident of 2 Ocean Drive, Tuna Compound, Quezon City, where he may be served
with summons and other pertinent processes.
[3] 2. Plaintiff owns that property located at 2 Ocean Drive, Tuna Compound, Quezon City
which it leased to defendant under the terms and conditions stated in the Contract of Lease dated
January 2005, which contract expires on December 2006. A copy of the contract is attached as ANNEX
A.
. Upon expiration of the contract, plaintiff informed defendant of its intention not to renew the
lease as it would use the property for its business expansion; plaintiff then asked defendant to vacate the
premises. A copy of plaintiffs letter to defendant is attached as ANNEX B.
[4] . Despite demand duly made and received, defendant has refused to vacate the premises
and continues to occupy the property without plaintiffs consent. Resort to the Barangay conciliation
system proved useless as defendant refused to appear before the Lupong Tagapamayapa. A Certification
to File Action is attached as ANNEX C.
5. Defendants act of dispossession has caused plaintiff to suffer material injury because
plaintiffs business expansion plans could not be implemented despite the arrival of machineries
specifically leased for this purpose at the rental rate of US$500 per month. Defendants continued
occupation of the premises has also forced plaintiff to sue and to incur legal expenses amounting to Fifty
Thousand Pesos (P50,000.00).
Comment [G19]: This particular

allegation may actually be unnecessary
considering the facts given and that the
plaintiff is a juridical person. It is included
in this complaint simply for educational
purposes as a representative allegation of
this fact.
[5] WHEREFORE, plaintiff respectfully prays for judgment in its favor by ordering defendant to
vacate the property and peacefully turn over possession to plaintiff and for defendant to pay plaintiff the
amount of US$3,500 representing rentals on the machineries for seven (7) months and Fifty Thousand
Pesos (P50,000.00) for Attorneys fees.
[6] Quezon City; 3 April 2007.
[7] (Sgd.) ATTICUS FINCH
Counsel for Plaintiff
[Address]
PLUS:
. [8] Verification and Certification against Forum Shopping
2. Jurat
Comment [G20]: A new requirement

specifically provided under Rule 7, section
2(d).
Comment [G21]: Significant amendment
introduced by 1997 Rules on Civil
Procedure; cf. Rule 7, section 3.
REGIONAL TRIAL COURT

Branch 01, Makati City
ESTA PADORA,
Plaintiff,
Civil Case No. 000882
For: Sum of Money
- versus -

5. Prayer/Reliefs
Forum Shopping
MANGGA GANTSO,
Defendant.
x -------------------------- x
COMPLAINT
[2] 1. Plaintiff is a Filipino, of legal age, and resident of 6750 Forbes Park, Makati City;
defendant is also a Filipino, of legal age and resident of 6752, Forbes Park, Makati City, where he may be
served with summons and other processes.
[3] 2. Sometime in January 2005 and over a period of six (6) months, defendant borrowed
certain amounts from plaintiff. Defendant promised to pay these amounts on an installment basis
monthly. These amounts now total Nine Hundred Thousand Pesos (P900,000.00).
[4] 3. Despite repeated demands, both oral and written, defendant failed or has refused to pay
any amount to plaintiff as no installment payment has even been made. A copy each of plaintiffs two (2)
demand letters is attached as ANNEX A and B.
. Resort to the Barangay Conciliation process proved fruitless as defendant failed to appear,
despite notice on him to appear. Thus, a Certification to File Action, a copy of which is attached as
ANNEX C, was issued by the Barangay Chairman.
5. Defendants obligation is due and demandable and plaintiff is entitled to the payment of the
entire amount of Nine Hundred Thousand Pesos (P900,000.00) plus legal interest.
6. By reason of defendants unreasonable failure or refusal to pay his due and demandable
obligation, plaintiff was forced to engage the services of counsel to vindicate his rights thereby
committing himself to pay legal expenses amounting to Fifty Thousand Pesos (P50,000.00).
[5] WHEREFORE, plaintiff respectfully prays for judgment in his favor through a Decision
directing defendant to pay him NINE HUNDRED THOUSAND PESOS (P900,000.00), with legal interest, as
ACTUAL DAMAGES and FIFTY THOUSAND PESOS (P50,000.00) as Attorneys Fees.
[6] Quezon City for Makati; 13 April 2007.
[Address]
PLUS: [8] Verification and Certification against Forum Shopping
Comment [G24]: Please note that this

portion is indispensable to the filing of a
Complaint as it is required that every
Complaint state in the body as well as in
the prayer the amount of damages sought.
This is jurisdictional and a complaint that
fails to comply with this requirement is
fatally defective.

Branch 101, Makati City
HURTS RENT-A-CAR,
represented by AKIN NAYAN,
Plaintiff,
- versus YOKO NGA,
Defendant.
x-----------------------------------x
COMPLAINT
Plaintiff, by counsel, respectfully states that:
[2] 1. Plaintiff is the general manager of Hurts Rent-A-Car with offices at Makati City; defendant
is a Tongan, temporarily residing at Bayview Hotel, Roxas Boulevard, Manila.
[3] 2. Hurts Rent-A-Car is the registered owner of a Honda CRV with license plate number XLV675, which defendant, on 3 March 2005, rented from plaintiff for a period of one (1) week.
[4] 3. On 15 March 2005, plaintiff demanded from defendant the return of the car but
defendant failed and refused to do so.
. The car has not been taken for a tax assessment or a fine pursuant to law nor has it been
seized on execution or attachment. Its present value is approximately Nine Hundred Thousand Pesos
(P900,000.00).
5. Plaintiff is ready, willing and able to give bond in defendants name in double the value of the
property for the return of the property to defendant should that be adjudged or for the payment of such
sum that defendant may recover from plaintiff in this action.
[5] WHEREFORE, plaintiff respectfully prays that the writ of replevin issue directing the Sheriff or
any other authorized officer to take possession of the car and dispose of it in accordancewith the Rules
of Court and, after hearing, judgment be rendered declaring plaintiff to be lawfully entitled to the
possession of the car and sentencing defendant to pay its value.
[6] Quezon City for Makati City; 13 April 2007.
[7] (Sgd.) MITCH MCDEERE
Counsel for the Plaintiff
[Address]

5. Prayer/Reliefs
Forum Shopping

Branch 161, Pasig City
NANG UUPA,
Plaintiff,
- versus NAGPA PAUPA,
Defendant.
x ---------------------- x
COMPLAINT
[2] 1. Plaintiff and Defendant are both Filipino citizens and of legal age; plaintiff resides at 1-A,
Cruz Street, Pasig City while defendant resides at 2 Frisco Street, Pasig City, where he may be served
with summons.
[3] 2. On 1 January 2003, defendant leased to plaintiff the premises at 1-A Cruz Street, Pasig
City for a monthly rental of One Thousand Pesos (P1,000.00) to be paid within the first five (5) days of
each month.
3. There is no fixed period for the lease agreement except that rentals are to be paid by the
month.
[4] . Plaintiff has been paying the rentals as they fall due each month, without fail. However,
on April 2006, defendant gave notice to plaintiff that he is terminating the lease agreement by the end
of August 2006.
5. Considering that the period of lease has not been fixed, this Honorable Court may fix a longer
period of time as the lessee has been occupying the place for a period of three (3) years. A period of two
(2) years is reasonable considering that the lessee has no place to transfer to immediately and that he
has introduced substantial improvements to the premises amounting to Fifty Thousand Pesos
(P50,000.00).
[5] WHEREFORE, it is respectfully prayed that this Honorable Court fix a period of years for the
lease between plaintiff and defendant.
[6] Quezon City for Pasig City; 13 April 2007.
[Address]
5. Prayer/Reliefs
Forum Shopping

Branch 33, Quezon City
ALIS DI-YAN COMPANY,
Plaintiff,
Civil Case No. 2222
For : Ejectment
- versus YOKO NGA,

Defendant.
x -----------------------------------x
ANSWER
(With COUNTERCLAIM)
DEFENDANT, by counsel, respectfully states that:
Admissions/Denials
[2] 1. He admits the contents of paragraph 1 only insofar as his personal circumstances but
specifically denies the contents insofar as plaintiffs personal circumstances for the reason stated in the
Affirmative Defenses below.
2. He admits the contents of paragraph 2 only where it states that a Contract of Lease was
entered into but specifically denies that the Contract reflects the true intent of the parties as explained in
the Affirmative Defenses below.
3. He admits the contents of paragraph 3 only as to the fact that demand to vacate was made
but specifically denies its contents as to the truth of the reasons for the letter for lack of knowledge
sufficient to form a reasonable belief as to its truth or falseness..
. He specifically denies the contents of paragraphs to 6 for the reasons stated in the
Affirmative Defenses below.
Affirmative Defenses
[4] 5. Defendant reiterates, repleads and incorporates by reference all the foregoing insofar as
they are material and additionally submit that the Complaint should be dismissed because:
5.1. Plaintiff has no capacity to sue as it is a foreign corporation doing business
in the Philippines without a license.
5.2. The Complaint fails to state a cause of action as the Contract of Lease
(ANNEX A) was, before its expiration, superceded by a Deed of Absolute Sale whereby
plaintiff sold to defendant the parcel of land in question, a copy of which is attached as
ANNEX 1.
Counterclaim
[5] 6. Defendant reiterates, repleads and incorporates by reference all the foregoing insofar as
they are material and additionally submit that he is entitled to relief arising from the filing of this
malicious and baseless suit, as follows:
6.1.
Moral Damages amounting to One Million Pesos (PHP1,000,000/00)
because his name and reputation were besmirched by this malicious and baseless suit.
6.2. Attorneys Fees amounting to One Hundred Thousand Pesos (P100,000.00)
because he was compelled to secure services of counsel to vindicate his legal rights.
[6] WHEREFORE, Defendant respectfully prays that judgment be rendered in his favor by
dismissing the Complaint and granting defendants counterclaim by awarding defendant: (a) One Million
Pesos as Moral Damages, and (b) Fifty Thousand as Attorneys Fees.
Other just and equitable reliefs are prayed for.
10
Defenses
5. Counterclaim
6. Prayer/Relief
9. Verification
10. Certification against Forum Shopping
11. Proof of Service

Exams
[Address]
[9 & 10] VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING
I, YOKO NGA, of legal age, do hereby state that: I am the defendant in the case filed by Alis Diyan Company for ejectment; in response, I have caused the preparation of this Answer with
Counterclaim; I have read its contents and affirm that they are true
and correct to the best of my own
e execution ell the

personal knowledge; I pecifically eny te genuineness
binding effect f the tionable ents pleaded by pl intiiff ; I hereby certify that there is no
other case commenced or pending before any court involving the same parties and the same issue and
that, should I learn of such a case, I shall notify the court within five (5) days from my notice.
IN WITNESS WHEREOF, I have signed this instrument on 13 April 2007.
(Sgd.) YOKO NGA
PLUS:
1. Jurat (IF any document is denied)
2. [11] Proof of Service (personal service or service by registered mail)
11
Comment [G30]: Rule 7, section 5

requires that any initiatory pleading,
among which is a counterclaim, must be
accompanied by a Certification against
Forum Shopping. Also please note that an
Answer need not be verified BUT if there
is a specific denial of an actionable
document, such as that contained here,
then the Answer must be verified. See
again Rule 8, secs. 7 (definition of
actionable document), 8 (how to contest
such documents), 10 (requirements of a
specific denial), 11 (effects of failure to
specifically deny).
Comment [G31]: Representative specific
denial under oath, as required by the
Rules, in relation to any actionable
document.
[5] Crossclim
7. Defendant reitertes, repleads nd incorortes by reference ll the foregoing insofr s they
re materi l nd dditionally submit that he is entitled to indemnity nd/or contribution from codefendant MANGGA GANTSO in the event that he is made lible to lintiff becse co-defendant
MANGGA GANTSO cted s the duly thorized gent of lintiff in the sale of the roperty nd, cting s
such, received considertion, in the form of the rchase rice, from defendant.
[6] WHEREFORE, Defendant respectf lly rys that j dgment be rendered in his fvor by
1. dismissing the Complaint, and
2. granting defendants counterclaim by awarding defendant
a. One Million Pesos (Php.1,000,000) as Moral Damages, and
b. Fifty Thousand Pesos (Php.50,000) as Attorneys Fees.
3. In the event that defendant is made liable to plaintiff on the Complaint, he further prays that
co-defendant MANGGA ANTSO be made liable to indemnify defendant in the same amount
under the Crossclaim.
[7] Quezon City; __________________.
[Address]
PLUS:
1. [9 & 10] Verification and Certification against Forum Shopping
2. Jurat (IF document is denied)
3. [11] Proof of Service (personal service or service by registered mail)
12
Defenses
5. Cross-claim
6. Prayer/Relief
9. Verification
10. Certification against Forum Shopping
11. Proof of Service

LAKISA LAYAW,
Plaintiff,
Civil Case No. 97-31312
4. Proposed stipulation of facts and issues

5. Documents to be presented
6. Names of witnesses and substance of
their testimony
7. Resort to discovery
8. Available trial dates
- versus LAKISA HIRAP,

Defendant.
x -------------------------------------x
PRE-TRIAL BRIEF
DEFENDANT, by counsel, respectfully submits her Pre-Trial Brief, as follows:
I. WILLINGNESS TO ENTER INTO AN AMICABLE SETTLEMENT
AND POSSIBLE TERMS OF ANY SUCH SETTLEMENT
1.1. Subject to a concrete proposal that is fair and reasonable and a reciprocal manifestation of
openness from plaintiff, defendant is open to the possibility of amicably settling this dispute.
[1 & 2] 1.2. Pursuant to Rule 18 of the 1997 Rules of Civil Procedure, defendant
respectfully submits that the desired terms of any amicable settlement would involve, first, a clarification
of the actual extent of any obligation due and owing to plaintiff inasmuch as there is nothing to indicate
defendants obligations to plaintiff and, second, a schedule of payments.
II. BRIEF STATEMENT OF CLAIMS AND DEFENSES
2.1. Plaintiff seeks principally to recover the amount of Twenty Two Million Eight Hundred
Eighteen Thousand Nine Hundred Forty Eight Pesos and Thirty Centavos (PHP22,818,948.30) with
interest at twelve percent (12%) arising allegedly from unpaid orders delivered to defendant variously in
1989.
2.2. Defendant resists plaintiffs claims based on a failure to state a cause of action because of :
2.2.1. Plaintiffs lack of personality to sue and, therefore, not being the real
party in interest under Rule 3, section 2 of the 1997 Rules of Civil Procedure;
2.2.2.
Furniture.
Extinguishment of the alleged claim made by the entity Regency
2.3.
Defendant also interposed a compulsory counterclaim for Two Million Pesos
(PHP2,000,000.00) for moral damages and Two Million Pesos (PHP2,000,000.00) for exemplary damages
and One Hundred Thousand Pesos (PHP100,000.00) as attorneys fees.
III. FACTS AND OTHER MATTERS ADMITTED BY THE PARTIES
[3] 3.1.
Defendant admits only those facts stated in her Answer, i.e., her personal
circumstances, receipt of the demand letter dated January 5, 1997 and her reply to the demand letter.
3.2. Subject to a concrete proposal for stipulation of additional facts from plaintiff during pre-trial
or even thereafter, defendant admits no other facts stated in the Complaint.
IV. ISSUES TO BE TRIED
[4] 4.1.
Defendant submits that the following issues put forward by plaintiff are subject to
proof:
4.1.1. Plaintiffs personality to seek legal relief;
4.1.2. Plaintiffs entitlement to the amount claimed;
4.2. Defendant submits that the following issues she put forward are subject to proof:
4.2.1. Plaintiffs bad faith in filing this suit;
13
Comment [G34]: NOTE: There is no need

to attach a Notice of Hearing for a Pre-Trial
Brief. Also, pre-trial is now mandatory in
criminal cases under Rule 118, 2000
Rules on Criminal Procedure as well as
under RA 8493 (The Speedy Trial Act),
although neither the law nor the Rules
require the submission of a Pre-Trial Brief
in criminal cases (in practice, courts also
do not require the submission of a pre-trial
brief in criminal cases). Consequently, the
requirement of a pre-trial brief and the
consequences for failure to submit one
(e.g., non-suit or dismissal) appear to
pertain exclusively to civil cases.
Comment [G35]: This is a new
requirement imposed by the 1997 Rules on
Civil Procedure.
[6] 5.1. Defendant intends to present the following witnesses:

5.1.1. Defendant herself, who will testify on the true circumstances leading to
the filing of this suit against her;
5.1.2. An employee of Topless Enterprises with personal knowledge as to the
true circumstances behind the alleged obligations due and owing in favor of plaintiff.
[5] 5.2. Defendant reserves the right to present any and all documentary evidence which shall
become relevant to rebut plaintiffs claims in the course of trial as well as any other witnesses whose
testimony will become relevant to belie plaintiffs witnesses, if necessary.
VI. RESORT TO DISCOVERY
[7] 6.1. Considering the relatively simple issues presented, defendant does not intend to avail of
discovery at this time.
6.2. Subject, however, to a concrete and reasonable request for discovery from plaintiff,
defendant reserves the right to resort to discovery before trial.
RESPECTFULLY SUBMITTED.
Quezon City; 13 April 2007.
[Address]
Copy furnished:
Atty. MA BOLA
14

3.
4.
5.
6.
7.
Prayer/Relief
Notice of Hearing
Proof of Service
Attachments (if any)
Verification (in certain cases)

Question
LAKI ASSET COMPANY,

Plaintiff,
Civil Case No. 3333
For: Sum of Money
- versus DAMI UTANG CORPORATION,

Defendant.
x ---------------------------------------x
MOTION TO DISMISS
DEFENDANT, by counsel, respectfully moves to dismiss the Complaint on the ground that the
Complaint fails to state a cause of action as [1] THE OBLIGATION SOUGHT TO BE ENFORCED BY
PLAINTIFF IS NOT YET DUE AND DEMANDABLE, as shown by the following:
[2] 1. Allegedly, plaintiff has failed to reach the quotas agreed upon under the Marketing
Agreement dated 1 January 2006; defendant now seeks to collect the sum of TWO HUNDRED
THOUSAND PESOS (P200,000.00), representing the balance of the proceeds due plaintiff under the said
Marketing Agreement.
2. The contract is for one (1) year and defendant is given that same period to reach the quota
specified therein; the period of one (1) year has not expired. Consequently, plaintiffs claim is premature
as there is yet no breach of the Marketing Agreement until the period expires and the quota is not
attained. For this reason, plaintiffs Complaint states no cause of action and must be dismissed.
[3] WHEREFORE, defendant respectfully prays that the Complaint be DISMISSED for failure to
state a cause of action.
[Address]
[4] REQUEST FOR & NOTICE OF HEARING
Comment [G38]: Rule 15, section 5; Cf.

Rule 15, section 4 (on period of service)

Metropolitan Trial Court
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, 27 April
2007 at 8:30 in the morning.
ATTICUS FINCH
1 MockingBird Street
Timog Avenue, Quezon City
Please take notice that counsel has requested to be heard on Friday, 27 April 2007 at 8:30 in the
morning.
2 The Firm
Comment [G39]: Rule 15, section 6 in
relation to Rule 13, section 13
PLUS: [5] Proof of Service
15
SUPREME COURT
Manila
LAKI UTANG,
Petitioner,
G.R. No. ________
- versus DAMI LUPA,
Respondent.
x ------------------------- x
MOTION FOR LEAVE
OF COURT TO FILE REPLY WITH
MOTION TO ADMIT ATTACHED REPLY
PETITIONER, by counsel, respectfully states that:
3.
4.
5.
6.
7.
Prayer/Relief
Notice of Hearing
Proof of Service
Comment [G41]: In motions filed before

the Supreme Court and the Court of
Appeals, a Notice of Hearing is not
required.
Comment [G42]: Under Rule 15, section

9, 1997 Rules on Civil Procedure, a motion
for leave to file a pleading or motion shall
be accompanied by the pleading or motion
sought to be admitted.
[1] 1. Petitioner received a copy of respondents Comment to his petition on 3 January 2006.
The Comment contains several allegations of fact and misinterpretations of the record that may mislead
the court and need to be corrected. For this reason, petitioner intends to file a Reply.
[2] 2. Under existing rules, a Reply can no longer be filed as a matter of course. Consequently,
petitioner seeks leave of this Court to file the said Reply, a copy of which, pursuant to the 1997 Rules on
Civil Procedure, is attached to this motion.
[3] WHEREFORE, petitioner respectfully prays that he be granted leave of court to file a Reply
and for the Court to admit the attached Reply.
Quezon City for Manila; 5 January 2007.
Counsel for the Petitioner
[Address]
PLUS:
1. [4] Request for and Notice of Hearing
2. [5] Explanation for service by registered mail
16
Comment [G43]: The requirement is for a

written explanation if service is done by
registered mail instead of by personal
service; the explanation need not be
verified, it being required only that it is
signed. However, in the Supreme Court,
where an Affidavit of Service is required, it
may be practical to combine the
Explanation and the Affidavit of Service. Cf.
Rule 13, sections 11 and 13.

LAKISA LAYAW,
Plaintiff,
4.
5.
6.
7.
Notice of Hearing
Proof of Service

For: Sum of Money

Defendant.
x ------------------------- x
MOTION FOR JUDGMENT ON THE PLEADINGS

Plaintiiff, by counsel, respectfully states that:
1. On 6 July 2005, plaintiff sued defendant for a sum of money in the amount of Nine Hundred
Thousand Pesos (P900,000.00).
[1 & 2] 2. In his Answer, defendant admitted the obligation and merely stated that he was
asking to be given an extension of time to pay his obligation but that plaintiff instead filed this Complaint.
The Answer admits the material allegations of the Complaint and has not tendered any issue;
consequently, a judgment on the pleadings may be rendered.
[3] WHEREFORE, plaintiff respectfully prays a judgment on the pleadings be rendered in his
favor.
[Address]
PLUS:
2. [5] Proof of Service
Comment [G46]: NOTE: This is a litigious

motion, i.e., it must be set for hearing.
Thus, a specific hearing date must be
requested and notice thereof given to
adverse party through counsel.
17

LAKISA LAYAW,
Plaintiff,
Defendant.
x ------------------------- x
denominated as ex parte, i.e., no need for

hearing.
Comment [G48]: Checklist:

1. Ground(s)
2. Argument(s)
3. Prayer/Relief
4. Notice of Hearing
5. Proof of Service
6. Attachments (if any)
7. Verification (in certain cases)
EX PARTE MOTION TO SET CASE FOR PRE-TRIAL

[1] 1. On 1 June 2006, defendant submitted her Answer to the Complaint, thereby causing the
issues to be joined.
[2] 2. This case is, thus, ripe for pre-trial. Complying with Rule 18, Section 1 of the 1997 Rules
on Civil Procedure, plaintiff respectfully asks that this case be set for pre-trial.
[3] WHEREFORE, plaintiff respectfully prays that this case be set for pre-trial on a date
convenient to this Honorable Court.
[Address]
[4] REQUEST AND NOTICE
Regional Trial Court
Please submit the foregoing to the Court for its approval immediately upon receipt hereof.
Copy furnished:
MITCH MCDEERE, ESQ.
2 The Firm
Please take notice that counsel has requested for the approval of the foregoing motion
immediately upon receipt.
PLUS: [5] Proof of Service
18
Comment [G49]: Note the difference

between this Request and Notice and that
contained in Form II-D1; this does not
contain a date of hearing because under
Rule 15, section 4, it is a motion which the
Court may act upon without prejudicing
the rights of the adverse party and
moreover because Rule 18, section 1
expressly defines this to be an ex parte
motion.

DILA TORY,
Plaintiff,
4.
5.
6.
7.
Notice of Hearing
Proof of Service

- versus PASEN SYOSO,
Defendant.
x ------------------------- x
MOTION FOR POSTPONEMENT
1. This case is set for trial on 5 May 2007 at 8:30 in the morning.
[1] 2. On said date and time, the undersigned counsel will be unable to appear before this
Honorable Court as he has also been directed to appear on this date and time before the Regional Trial
Court of Makati City, Branch 139 for People of the Philippines v. Bil Moko, Criminal Case No. 009988,
where he is scheduled to terminate cross-examination of the prosecutions expert witness who will be
available only on said date and time.
[2] 3. Without impugning the importance of these proceedings, plaintiff respectfully submits
that his attendance in the Makati case becomes indispensable; otherwise, the accused in said case would
be deprived of the opportunity to confront and cross-examine a vital witness against her.
4. This motion is prompted only by the foregoing reason and not for delay.
[3] WHEREFORE, plaintiff respectfully prays that the trial scheduled on 5 May 2007 be
POSTPONED to another date convenient to this Honorable Court.
[Address]
PLUS:
Comment [G52]: In some instances, this

motion is considered a non-litigious
motion; thus, the request and notice need
not specify a date of hearing and simply
state that it is being submitted for approval
immediately upon receipt. Although, the
better practice would be to file such a
motion early so as to be able to set it for
hearing and approval by the court.
19

5. Proof of Service
DILA TORY,
Plaintiff,
- versus PASEN SYOSO,
Defendant.
x ------------------------------------x
MOTION FOR EXTENSION OF TIME
1. He has been directed to file a Reply to defendants Answer by 10 May 2007.
[1 & 2] 2. The undersigned counsel, however, anticipates his inability to file the Reply on or
before the said due date because of the tremendous pressure of other equally urgent professional work
requiring the preparation of pleadings and almost daily trial appearances before the various courts within
and outside Metro Manila. For this reason, the undersigned is constrained to ask for an additional fifteen
(15) days from 10 May 2007, or until 25 May 2007, within which to submit plaintiffs Reply.
3. This motion is not intended for delay but is motivated only by the foregoing reason.
[3] WHEREFORE, plaintiff respectfully prays that he be granted an additional fifteen (15) days
from 10 May 2007, or until 25 May 2007, within which to submit plaintiffs Reply.
[Address]
PLUS:
20
Comment [G54]: It is always preferable to

not only state the number of additional
days sought, but also the new deadline, so
that it can be used as a personal reminder
of the new deadline.

5. Proof of Service
ANAKIN SKYWALKER,
Plaintiff,
- versus PADME AMIDALA,
Defendant.
x ---------------------------------- x
MOTION TO DECLARE DEFENDANT IN DEFAULT
1. Plaintiff filed this Complaint against defendant on 1 March 2007; summons were served on
defendant on 20 March 2007, as indicated by the Sheriffs Return of even date, a copy of which is
attached as ANNEX A.
[1 & 2] 2. Defendants reglementary period to file Answer ended on 5 April 2007; no motion for
extension of such period was filed nor was any granted motu proprio by this Honorable Court. Despite
the lapse of time, defendant has failed to answer the Complaint against her; plaintiff is entitled to a
declaration of default and the right to present evidence ex parte against defendant.
[3] WHEREFORE, plaintiff respectfully prays that defendant be declared in default and that
plaintiff be allowed to present evidence ex parte before the Clerk of Court acting as Commissioner.
(Sgd.) DARTH SIDIOUS
[Address]
PLUS:
Comment [G56]: NOTE: The defendant is

entitled to be notified of this motion and
the order declaring him/her in default;
thereafter, defendant loses the right to
receive any other notices except for
judgment in default.
21

ANAKIN SKYWALKER,
Plaintiff,
4.
5.
6.
7.
Notice of Hearing
Proof of Service

Defendant.
x ----------------------------------x
MOTION TO LIFT ORDER OF DEFAULT
DEFENDANT, by counsel, respectfully states that:
1. Five (5) days after service of summons and receipt of Complaint, she filed a Motion to Dismiss
on the ground that plaintiffs claim is outside the jurisdictional amount of this Honorable Court under the
new Expanded Jurisdiction Act and that the Complaint should properly be filed and tried before the
Metropolitan Trial Court. The Motion to Dismiss, which was received by plaintiffs counsel on 25 March
2007, was set for hearing on 10 April 2007, as indicated on the Request for and Notice of Hearing.
2. Without waiting for the hearing on the Motion to Dismiss, this Honorable Court declared
defendant in default on 7 April 2007 based solely on plaintiffs Motion, filed two (2) days after the
supposed lapse of the reglementary period, which, however, was tolled by the filing of a Motion to
Dismiss.
[1 & 2] 3. Under the circumstances, the order of default is premature and without legal and
factual basis as: (a) defendant has not failed to file an Answer within the reglementary period, (b) the
reglementary period has not lapsed because of the filing of the Motion to Dismiss within the period, and
(c) the pendency of the Motion to Dismiss is prejudicial to the issue of defendants default. Consequently,
the order of default should be lifted.
[3] WHEREFORE, defendant respectfully prays that the Order of Default against her be LIFTED
and that this Honorable Court resolve her Motion to Dismiss.
(Sgd.) OBI WAN KENOBI
[Address]
PLUS:
22
Comment [G59]: While it is not required,

it may, depending on the type of motion, be
advisable to give a short summary of the
material antecedents so that the
arguments and the basis for relief is clear
and placed in context.
(Caption and Title)

PETITION
[2] 1. (tate capacity of petitioner and respondent/s, citizenship, status and residence.)
2. (tate the date on hich copy of
Reconsideration, if filed, denied.)
ecision as received and/or Resolution on
otion for
order (cf. Rule 65, sec. 4)

2. Names of petitioner and respondent
3. Grounds relied upon
4. Prayer/Relief
5. Combined Verification, Certification
against Forum Shopping, and Statement of
Material Dates
6. Attachments
a. Certified true copies of the
judgment/order subject of petition
b. All material portions of the record as
would support the petition*
[3] 3. (tate briefly the facts and circumstances under hich the respondent/s exercising
judicial functions acted ithout, or in excess of, jurisdiction or ith rave abuse of discretion amounting
to lack or excess of jurisdiction.)
4. (tate entitlement to Injunction and/or TRO, i.e., [a] petitioner has a clear, legal riht, [b]
hich is threatened by an act or omission of respondents, [c] and that, unless restrained, ill cause
rave and irreparable injury to petitioner. llege also that petitioner is ready to post a bond in an amount
to be fixed by the Court conditioned upon the pay ent to respondents of any damages suffered arising
from the rit should petitioner be found not to be entitled to the rit.)
5. There is no appeal from such decision or any plain or adequate speedy remedy in the ordinary
course of law, except this petition.
6. certified true copy (or duplicate oriinal copy) of the
NNEX .
ecision under review is attached as
[4] WHEREFORE, it is respectfully prayed that a rit of certiorari be issued NNULLING the (act,
decision or finding) for being in rave abuse of discretion; in the interi , that a preli inary injunction
and/or temporary restraining order issue to ENJOIN any further proceedings by respondents.
Quezon City; [1] 7 July 2007.
(d.) TTICUS FINCH
[ddress]
PLUS: [5] Combined Verification, Certification against Forum hopping, and tatement of
aterial
ates
* Rule 65, section 6, par. 2 expressly akes Rule 56, section 2 applicable to petitions for certiorari,
andamus and prohibition. Rule 56, section 2 provides that Rules 46, 48, 49, 51, 52 and 56 apply. Rule
46, section 3 provides that the petition must be accompanied not only by a certified true copy of
the judgment or order questioned but also by such material portions of the record as are
referred to therein, and other documents, relevant or pertinent thereto .
23
Comment [G61]: To the standard

Verification and Certification Against
Forum Shopping, ADD the date when the
Decision or Judgment was received
pursuant to the requirements under the
Rules of Court. (See Form I-G)
PETITION
[2] 1. (tate capacity of petitioner and respondent/s, citizenship, status and residence.)
2. (If applicable, state the date on hich copy of

otion for Reconsideration, if filed, denied.)
ecision as received and/or Resolution on
3. Grounds relied upon

4. Prayer/Relief
Material Dates
6. Attachments
[3] 3. (tate briefly the facts and circumstances under hich the respondent/s hether
exercising judicial or inisterial functions acted ithout, or in excess of, jurisdiction or ith rave abuse
of discretion amounting to lack or excess of jurisdiction.)
4. (tate entitlement to Injunction and/or TRO, i.e., [a] petitioner has a clear, legal ri ht, [b]
hich is threatened by an act or omission of respondents, [c] and that, unless restrained, ill cause
rave and irreparable injury to petitioner. llege also that petitioner is ready to post a bond in an
amount to be fixed by the Court conditioned upon the payent to respondents of any damages suffered
arising from the rit should petitioner be found not to be entitled to the rit.)
5. There is no appeal from such decision or any plain or adequate speedy remedy in the ordinary
course of law, except this petition.
6.
certified true copy (or duplicate ori inal copy) of the
ecision under review is attached as
NNEX .
[4] WHEREFORE, it is respectfully prayed that an injunction or TRO be issued directing

respondent/s to desist and refrain from further proceedings in the premises, and that after due notice
and hearing, a rit of prohibition issue directing respondent/s to desist absolute and perpetually from
further proceedings (in the said action or atter).
( d.) TTICUS FINCH

Counsel for
the Petitioner
[ ddress]
PLUS: [5] Combined Verification, Certification against Forum hopping, and tatement of
24
aterial
ates
Comment [G64]: To the standard

Verification and Certification Against
Forum Shopping, ADD the date when the
Decision or Judgment was received
pursuant to the requirements under the
Rules of Court. (See Form I-G)
PETITION
[2] 1. ( tate the capacity of petitioner and respondent/s and their addresses.)
[3] 2. ( tate the facts and circumstances hereby respondent/s unlawfully neglected the
perforance of an act hich the law specifically enjoins as a duty resulting from an office, trust or
station, or unlawfully excluded the petitioner from the enjoyent of a riht or office to hich the
petitioner is entitled.)
3. Petitioner has no appeal from such decision or any plain or adequate speedy remedy in the
ordinary course of law, except this petition.
[4] WHEREFORE, it is respectfully prayed that, after due notice and hearing, a rit of andamus
issue commanding respondent/s forthwith to: (state the act required to be done), ith costs against
them.
( d.) ATTICUS FINCH

[Address]
PLUS: [5] Combined Verification, Certification against Forum hopping, and tatement of Material Dates
25
4. Prayer/Relief
Material Dates
6. Attachments
Plaintiff,
SCA No. ____________
- versus UMA AGAW and INA AGAWAN,
Defendants.
x ---------------------------------------x
COMPLAINT
claimants; and claimants over the same

subject matter
2. Material Allegations of Ultimate Facts facts showing conflicting claims made on
the same subject matter over which
petitioner claims no interest or an interest
that is not disputed by claimants
3. Prayer/Relief
6. Verification and Certification against
Forum Shopping
Comment [G67]: 1995 Bar Question
[1] 1. Plaintiff and defendants are all of legal age; plaintiff resides at ________________ while
defendants reside at _______________ and _______________, respectively, where they may be served
with pertinent notices.
[2] 2. On 1 June 2007, plaintiff found a Gold Rolex Oyster watch, without knowing who its true
owner is. The watch is now in plaintiffs possession. On or about 5 June 1999, defendants made similar
representations to plaintiff as to ownership of the watch.
3. Plaintiff, who claims no interest in the watch, cannot determine the conflicting claims of
defendants and thus seeks to compel defendants to interplead and litigate their several claims between
themselves.
[3] WHEREFORE, it is respectfully prayed that this Honorable Court issue an order directing
defendants to interplead with one another to determine their respective rights and claims and to allow
plaintiff to recover his expenses for safekeeping and the costs of this suit, as first lien upon the subject
matter of this action.
[4] Quezon City; 7 July 2007.

[Address]
26
Comment [G68]: It is important to allege

this because otherwise plaintiff would be
required to pay the docket fees involved in
filing the Complaint in Interpleader which
would be determined by the value of the
property. In this way, plaintiff will not be
unduly prejudiced by the costs of the suit.
SCA No. 1357

NALI LITO, as Special Administrator of the
Estate of the deceased DAMI LUPA,
Petitioner,
UMA AGAW,
Respondent.
x ------------------------------------------------x
PETITION
[1] 1. He is the special administrator of the estate of the deceased DAMI LUPA.
[2] 2. The deceased, during his lifetime, executed a Deed of Sale of real estate in favor of the
respondent dated _____________, and particularly described, as follows:
(Describe property)
covered by TCT No. 12345 in the Register of Deeds of Makati. The same is annotated on the title as the
only encumbrance thereon.
3. The sale is fictitious and the Deed of Sale is forged, as shown by a judgment in Civil Case No.
2468, a copy of which is attached.
4. The existence of the alleged Deed of Sale is prejudicial and injurious to the title of the lawful
heirs of the deceased upon the said property. Equity demands that the said Deed of Sale be surrendered
and cancelled, as it is a cloud upon the title of the deceased and his lawful heirs.
[3] WHEREFORE, petitioner respectfully prays that this Honorable Court render judgment in the
Estates favor by ordering the Deed of Sale surrendered and cancelled and the cloud on Title No. 12345
removed.
Counsel for Petitioner
[Address]
27
injury by operation of the said deed, will,

contract or other writing
2. Material Allegations of Ultimate Facts facts showing interest under a deed, will,
contract or other written instrument and
injury arising from operation of said deed,
will, contract or other writing and facts
showing that no violation or breach has
occurred; may also show facts showing
need to reform instrument , quiet title
(arising from conflicting claims or cloud
thereon) or to consolidate ownership (as
when property under pacto de retro not
redeemed)
3. Prayer/Relief
Forum Shopping
- versus -
Civil Case No. 2468
THE CITY COUNCIL

OF QUEZON CITY,
Defendant.
x --------------------------- x
COMPLAINT
[1] 1. Plaintiff is a Filipino citizen of legal age and resident of Quezon City; defendant is the City
Council of Quezon City, the duly-constituted legislative body for Quezon City, its members may be served
with notices at Quezon City Hall.
[2] 2. On 1 August 1999, defendant City Council passed Ordinance No. 2345 making it unlawful
to operate cellular phone units while inside a moving vehicle and penalizing any violations with a fine of
P1,000.00 for each offense in addition to impounding of the cellular phone unit. The relevant portions of
the Ordinance are, as follows:
(Quote the relevant portions)
3. The above-quoted portion is ambiguous because it leaves unfettered discretion to the
authorities to stop even urgent and important calls which may be made only while the person is in
transit. It fails to consider that, due to the worsening traffic conditions in Metro Manila, majority of
business is conducted in transit and over cellular phones. Plaintiff is a lawyer who frequently has to
dictate important pleadings over the phone while in transit due to the worsening traffic condition. The
Ordinance appears to bar his doing so but plaintiff is unaware of the limits of permissible action under the
Ordinance.
4. Unless declaratory relief is granted, plaintiff will suffer grave and irreparable injury because he
is unsure of the instances when he may lawfully use his cellular phone while in a moving vehicle and
when such use may lead to confiscation and a fine.
[3] WHEREFORE, plaintiff respectfully prays that this Honorable Court grant declaratory relief
and declare plaintiffs rights and duties under the Ordinance.
[Address]
28
injury by operation of the said deed, will,

contract or other writing
2. Material Allegations of Ultimate Facts facts showing interest under a deed, will,
contract or other written instrument and
injury arising from operation of said deed,
will, contract or other writing and facts
showing that no violation or breach has
occurred; may also show facts showing
need to reform instrument , quiet title
(arising from conflicting claims or cloud
thereon) or to consolidate ownership (as
when property under pacto de retro not
redeemed)
3. Prayer/Relief
Forum Shopping
COMPLAINT
[1] 1. (tate the capacity and address of both plaintiff and defendant.)
[2] 2. (tate fully and clearly the facts and circumstances showing that defendant is unlawfully
occupying a public office and that plaintiff is entitled to hold the same office.)
3. (tate that plaintiff has demanded that defendant vacate said office and deliver it to plaintiff
but that defendant has unlawfully refused to do so.)
[3] WHEREFORE, plaintiff respectfully prays that a rit of quo arranto issue ousting and
excluding defendant from occupying the office of ____________ and declare that plaintiff is entitled to
the said office and that he be placed forthwith in possession thereof.
[5] ( d.) ATTICUS FINCH

[Address]
PLUS: [6] Verification and Certification against Forum hopping
29
b. Person claiming to be entitled to

public office or position usurped or
unlawfully held or exercised by another
against the alleged usurping public officer;
2. Material Allegations of Ultimate Facts facts showing usurpation of office and facts
showing entitlement of petitioner to the
office
3. Prayer/Relief
Forum Shopping

City of Makati
)
) s.s.
COMPLAIT-AFFIDAVIT
[1] I, MA SELAN, of legal age, Filipino, ith assistance of counsel, and [2] resident of 4 Privet
Drive, Triple X Village, Makati, do hereby state under oath that:
1. I am a member of the Triple X Village Homeowners Association (Association) and as
formerly a Director and Corporate Secretary of the Association.
[3] 2. I accuse and hereby charge MR. MA INGAY, residing at 5 Privet Drive, Triple X Village,
Makati, of violating Article 358 of the Revised Penal Code (Slander and Oral Defamation), committed
against me hen he publicly, maliciously and deliberately uttered defamatory remarks against me during
the Board Meeting of the Association on 27 January 2007. This is attested to by the following exchange
that transpired bet een Mr. Ingay and the other members of the Board in attendance:
3. Factual allegations to show violation or

defense
4. Signature of affiant
5. Verification
6. Certification as to Personal Examination
of Affiant
7. Supporting Documents/Affidavits
Comment [FG73]: Because an affidavit

must be based on personal knowledge of
the affiant, many times, legal answers
cannot be included for fear that affiant
does NOT have personal knowledge.
Stating that affiant was assisted by counsel
may remove that problem as all that affiant
has to do is say I was advised by counsel
that
(Quote Exchange)
Attached as ANNEX A is a copy of the official transcript of the meeting.
3. Prior resort to the Barangay conciliation system proved fruitless as Mr. Ingay did not retract
his remarks. Consequently, a Certification
to File Action as issued by the Barangay Chairperson, a
copy of hich is attached as ANNEX .

4. There is no other person named Ma Selan residing at Triple X Village nor is there any other
person named Ma Selan ho has acted as Board Member of the Association. Consequently, Mr. Ingays
public and defamatory utterance as clearly a reference to me and to no other.
5. Mr. Ma Ingays remarks, calling me a s indler t ice over, uttered in a public meeting are
clearly insulting and defamatory as they malign me and attribute to me a criminal act, nature and
predisposition. There is, moreover, no doubt that Mr. Ingays use of the ord s indled as deliberate
as his explanation and clarification a few utterances thereafter ould show. Mr. Ingays remarks are also
very serious as they cast aspersions on my reputation, character and very person before my peers and
fellow homeowners.
6. Mr. Ingays remarks have injured my name, reputation and character before my neighbors
and peers. While my name, reputation and character are incapable of pecuniary estimation as these are
the result of a lifetimes effort to build a name, reputation and character that my children and their
children can be proud to bear, Mr. Ingay cannot be allowed to simply go scot-free ithout bearing the
consequences of his acts. For this reason, I am also holding Mr. Ma Ingay liable civilly for
defaming me in the amount of One Million Pesos (P1,000,000.00) in nominal damages, Five
Hundred Thousand Pesos (P500,000.00) in moral damages and Five Hundred Thousand
Pesos (P500,000.00) in exemplary damages.
TO THE TRUTH OF THE FOREGOING, I have signed this Complaint-Affidavit on 13 April 2007.
[4] (Sgd.) MA SELAN
Complainant-Affiant
[5] SUBSCRIBED AND SWORN TO BEFORE ME this 13th day of April 2007.
(Sgd.) Investigating Prosecutor
[6] CERTIFICATION
I HEREBY CERTIFY THAT I HAVE PERSONALLY EXAMINED THE AFFIANT AND AM SATISFIED
THAT HE VOLUNTARILY EXECUTED AND UNDERSTOOD HIS AFFIDAVIT.
(Sgd.) Investigating Prosecutor
30
Comment [FG74]: Rule 112, sec. 3(a),

2000 Rules on Criminal Procedure. Note
that this may be done before a prosecutor,
or any government official authorized to
administer an oath, or in their absence or
unavailability, a Notary Public.
COUNTER-AFFIDAVIT
Re: I.S. No. 1613
[1] I, MA LABO, of legal age, ith assistance of counsel, do hereby state under oath that:
1. I am the Chief of Staff of the Mayor of Quezon City, and have been occupying said post since
his election to the post in 1998. In said capacity, I am in charge of coordinating the day-to-day affairs
and activities of his Office.
[2] 2. I recently learned that I have been made a respondent in I.S. No. 1613, a charge for
estafa, filed by a certain MA GULANG on 19 January 2007 before the Office of the City Prosecutor for
Quezon City.
3. The charge is based on a supposedly unpaid account for the purchase of seven (7) Nextel
phone units by a Mr. MANGGA GANTSO of the Quezon City Rescue and Environmental Distress Unit,
hich made the Mayor their Honorary Chairman ith no direct functions; he has been supporting their
activities financially ith voluntary contributions.
[3] 4. There is no truth to the allegations in MA GULANGs complaint. There is no factual nor
legal basis to charge me ith estafa. The Complaint must be dismissed. To rebut and contradict MA
GULANGs malicious lies, I set forth the true circumstances leading to the transaction below:
4.1. Sometime last year, Ms. Gulang called the office of the Mayor, looking for
him; I informed her that he as not around. I took a message from her saying that she
as a friend of the Mayor and that she as selling Nextel units and if e anted to buy
units from her. I informed her that both the Mayor and I had our units already; she then
told me if the Mayor could refer her to prospective clients. When the Mayor arrived, I
relayed the message to him.
4.2. Quite coincidentally, Mr. Gantso had called the Mayor asking if he could
assist in securing Nextel units. The Mayor asked me to call Ms. Gulang. Mr. Gantso and
Ms. Gulang ere able to meet, as a result.
4.3. On that day, Ms. Gulang brought the units to the Mayors Office; she met
ith Mr. Gantso inside the Mayors office. They transacted business inside the Mayors
Office and only passed by my office on their ay out.
4.4. Some time after that, Ms. Gulang phoned me and told me that Mr. Gantso
had not paid her the amount of P11,000.00 for the units. Somewhat embarrassed by
this, I called Mr. Gantso and told him to pay Ms. Gulang; he assured me that he ould
pay her but that he just needed to collect money from the rest of the group.
4.5. After persistent calls from Ms. Gulang telling me that Mr. Gantso had not
yet paid, I gave her the telephone number of Gantso so that she could just call him
directly. But even then, I ould still get calls from Ms. Gulang; and hen she started to
get angry over the telephone, I set up an appointment for Mr. Gantso to meet ith her
at the Office.
4.6. Thereafter, I ould still receive phone calls telling me that Mr. Gantso had
yet to pay; I ould follow up ith Mr. Gantso but he simply gave me this promise that he
ould pay.
5. It is utterly inexplicable that Ms. Gulang ould hold me liable for estafa hen all that I did
as to refer Ms. Gulang to Mr. Gantso; to a certain extent, I even exerted my best efforts to see that Ms.
Gulang as paid due simply to my great embarrassment at the prospect of being accused of referring a
person ho does not know how to pay for an obligation.
6. For this reason, it is certainly incomprehensible that I should stand accused of estafa by Ms.
Gulang. I performed no act of deceit or fraud against her in ordering the units. I performed
NO ACT that even remotely resembles ANY of the acts punished unde r Article 315. If at all,
any cause of action is PURELY CIVIL in nature and that liability does not pertain to my personal account
in the absence of a showing that I benefited from the Nextel units ( hich Ms. Gulang does not even
allege and cannot prove); any civil liability should pertain to the Office of the Mayor, not to me.
31
defense
4. Signature of affiant
5. Verification
6. Certification as to Personal Examination
of Affiant
7. Supporting Documents/Affidavits
Comment [FG76]: Because an affidavit

must be based on personal knowledge of
the affiant, many times, legal answers
cannot be included for fear that affiant
does NOT have personal knowledge.
Stating that affiant was assisted by counsel
may remove that problem as all that affiant
has to do is say I was advised by counsel
that
TO THE TRUTH OF THE FOREGOING, I have signed this Statement on 3 February 2007.
[4] (Sgd.) MA LABO
Affiant
PLUS:
1. [5] Verification
2. [6] Certification
32
(Caption)
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Criminal Case No. 00567
For: Bigamy
- versus PI KUTIN,
Accused.
x ----------------------------------------x
INFORMATION
The Undersigned accuses PI KUTIN of the crime of Bigamy, committed as follows:

That on or about 3 July 2006, in the City of Quezon and within the jurisdiction of
this Honorable Court, the said accused, being then legally married to BIL MOKO, and
without such marriage having been legally dissolved and thus valid and existing, did
wilfully, unlawfully and felicitously contract a second marriage with ASA WA in the City of
Quezon.
b. Name of accused
2. Designation of offense by statute
3. Acts or omissions complained of as
constituting the offense including a
statement of the qualifying or aggravating
circumstances
4. Approximate time of the commission of
the offense
5. Place of commission
6. Signature of Prosecutor (for Information)
7. Signature of Offended Party, Peace
officer or Public officer charged with
enforcement of the law (for Complaint)
8. NOTE: if Information is filed after
inquest (and not preliminary investigation),
ADD:
a. Place where accused is actually
detained
b. Full name and address of evidence
custodian
c. Detailed description of recovered
items, if any
9. Verification
10. Certification of Preliminary
Investigation or Inquest
Comment [FG78]: 1989 Bar Question
CONTRARY TO LAW.
Comment [FG79]: NOTE: The allegation of

any aggravating circumstances should be
made here.
ELLIOT NESS
Assistant City Prosecutor
CERTIFICATE OF PRELIMINARY INVESTIGATION

I hereby certify that a preliminary investigation in this case was conducted by me in accordance
with law; that I examined the Complainant and her witnesses; that there is reasonable ground to believe
that the offense charged had been committed and that the accused is probably guilty thereof; that the
accused was informed of the Complaint and of the evidence submitted against him and was given the
opportunity to submit controverting evidence; and that the filing of this Information is with the prior
authority and approval of the City Prosecutor.
ELLIOT NESS
Comment [FG80]: See Rule 112, section 4,

2000 Rules on Criminal Procedure. This
Certification is appended to an Information
filed after a full blown preliminary
investigation is conducted; if the accused
was arrested without a warrant and
refused/failed to execute a written waiver
of the provisions of Article 125, Revised
Penal Code, the ACP should have
conducted an INQUEST and not a
preliminary investigation. Any Information
filed would thus have a different
Certification, i.e., a Certification on
Conduct of Inquest.
SUBSCRIBED AND SWORN TO BEFORE ME this 9th day of August 2006 in Quezon City.
AL CAPONE
City Prosecutor
Bail Recommended: P10,000.00
33
Comment [FG81]: See Rule 110, sections

3, 4, 2000 Rules on Criminal Procedure.
Please note that the oath is administered
by a public officer authorized to administer
an oath; thus, the JURAT does not contain
any reference to the CTC details. Contrast
this with the Jurat in Form I-C, which
applies when a Notary Public administers
the oath.

Plaintiff,
For: Theft
- versus KLEPTO MANIAC,

Accused.
x ---------------------------------------------x
INFORMATION
The Undersigned accuses KLEPTO MANIAC of the crime of Theft, committed as follows:
That on or about 3 July 2006, in the City of Quezon and within
the jurisdiction of this Honorable Court, the said accused, then 11 years
old and without any known address, willfully, unlawfully and feloniously,
with intent to gain, without force upon things or violence upon persons
and without the knowledge and consent of MA ALAHAS, the owner, took
a gold necklace studded with diamonds valued at One Hundred
Thousand Pesos (P100,000.00) to the prejudice of said owner.

circumstances
the offense
ADD:
detained
custodian
items, if any
9. Verification
CONTRARY TO LAW.
ELLIOT NESS
CERTIFICATION AS TO CONDUCT OF INQUEST
I hereby certify that the accused was lawfully arrested without a warrant and that, upon being
informed of his rights, refused to waive the provisions of Article 125 of the Revised Penal Code and, for
this reason, an Inquest was conducted; that based on the complaint and the evidence presented before
me without any countervailing evidence submitted by the accused, despite opportunity to do so, there is
reasonable ground to believe that the accused has committed the crime of theft and should, thus, be
held for said crime; that this Information was with the prior authority of the City Prosecutor.
ELLIOT NESS
SUBSCRIBED AND SWORN TO BEFORE ME this 9th of August 2006 in Quezon City.
AL CAPONE
City Prosecutor
34
Comment [FG84]: See DOJ Circular No.

61 (September 21, 1993; New Rules on
Inquest), section 14. As noted above, this
Certification accompanies an Information
filed after an inquest and not a preliminary
investigation is conducted. An inquest is
conducted only if the respondent was
arrested without a warrant and does not
waive the provisions of Article 125 of the
RPC and does not wish to avail of a fullblown preliminary investigation.

Plaintiff,
For: Attempted Rape
- versus MAEL SIA,

Accused.
x --------------------------------------------- x
INFORMATION
The undersigned accuses MAEL SIA of attempted rape committed as follows:

That on or about 6 June 2005, in Quezon City, the accused did then and there
wilfully, unlawfully and feloniously enter the house of SEK SEE, a married woman, and
finding that her husband was away, with lewd designs and by means of force and
intimidation, commenced directly by overt acts to commit the crime of attempted rape
upon her person, to wit: while SEK SEE was cooking lunch, the accused seized herfrom
behind, threw her to the floor, raised her skirt, pulled down her underwear and
attempted to penetrate her with his sexual organ and would have succeeded in doing so
had not her loud protests and vigorous resistance brought her neighbors to her
assistance, causing the accused to flee from the premises without completing all the acts
of execution.
CONTRARY TO LAW with the aggravating circumstance of dwelling.
ELLIOT NESS
PLUS: Certification of Preliminary Investigation or Inquest
35
2. Designation of offense by statute

circumstances
the offense
ADD:
detained
custodian
items, if any
9. Verification

Plaintiff,
For: Frustrated Murder
- versus MAMA MATAY,

Accused.
x ---------------------------------------------x
INFORMATION
The undersigned accuses MAMA MATAY of frustrated murder committed as follows:

That on or about 21 August 2006, in Quezon City, the accused did then and
there take a loaded .44 Caliber Magnum pistol, directly aim the same firearm at the
person of VIC TIMA, an invalid septuagenarian, and, at point blank range, with intent to
kill, discharge the firearm twice against the person of said Vic Tima, inflicting on said Vic
Tima two (2) wounds on his chest and stomach, which wounds would have been fatal
had not timely medical assistance been rendered to the said Vic Tima.
CONTRARY TO LAW with the aggravating
Premeditation, use of firearm and disregard of age.
(Sgd.) ELLIOT NESS
PLUS: Certification of Preliminary Investigation or Inquest
36
circumstances
of
Evident

circumstances
the offense
ADD:
detained
custodian
items, if any
9. Verification

Plaintiff,
For: Theft
- versus KLEPTO MANIAC,

Accused.
x ------------------------------------------x
MOTION TO QUASH
[2] THE ACCUSED, by counsel, respectfully moves to quash the Information for the crime of
theft on the following:
[3] GROUNDS
1. IT CONTAINS AVERMENTS WHICH, IF TRUE, WOULD CONSTITUTE A LEGAL
JUSTIFICATION;
2. THIS COURT IS WITHOUT JURISDICTION.
In support, the accused respectfully states that:
ARGUMENT
The Information alleges that the accused KLEPTO MANIAC is eleven (11) years old and without
any known address. Under Article 12, paragraph 3 of the Revised Penal Code, a person over nine years of
age and under fifteen, unless he acted with discernment, is exempt from criminal liability.
There is no allegation that the accused acted with discernment. Even granting said discernment,
the accused cannot be tried but instead proceeded against under Article 80 of the Revised Penal Code,
which provides that a minor, unless sixteen years of age at the time of the commission of a grave or less
grave felony, cannot be tried but instead shall have the benefit of a suspension of all proceedings against
him. The duty of the court would be to commit the minor to the custody or care of a public or private
benevolent or charitable institution for the care and education of homeless and delinquent children or to
the custody of the Department of Social Work and Development.
[4] WHEREFORE, it is respectfully prayed that the Information against the accused be QUASHED
and that the accused be released immediately from detention.
Counsel for the Accused
[Address]
PLUS:
37
3. Distinct specification of factual and legal

grounds for quashal
4. Relief
5. Date/Place
6. Signature of counsel
8. Affidavit of service
Comment [FG89]: 1976, 1986, 1988 and

1990 Bar Question
Plaintiff,
- versus -

For: Libel
VIG CHAN,
Accused.
x ----------------------------------------------x
MOTION TO QUASH SEARCH WARRANT
The ACCUSED, by counsel, respectfully moves for the quashal of Search Warrant No. 1122 issued
by this Honorable Court on and dated 12 July 2006 based on the following considerations:
[2] 1. Rule 126, Sec. 10 or the Revised Rules of Court provides expressly that a search warrant
shall be valid for ten (10) days from its date and that thereafter, it shall be void.
2. Search Warrant No. 1122 is dated 12 July 2006. It was served on the accused on 23 July
2006, the 11th day from its date; this is certified to by the Sworn Inventory and Return executed by Major
Alang Alam, the leader of the searching team (a copy of which is already part of the records). A search
was made on the same day, 23 July 2006; pursuant to said search, certain objects were seized and
delivered to the court. Under the law, the Search Warrant is void and must, thus, be quashed.
[3] WHEREFORE, it is respectfully prayed that Search Warrant No. 1122 be QUASHED and all
objects seized under its purported authority be declared INADMISSIBLE under the exclusionary rule in
Article III, Section 3(2) in relation to section 2 of the 1987 Constitution.
[5] (Sgd.) MA TAPANG
Counsel for Accused
[Address]
PLUS:
38
acknowledged by the Supreme Court in

case law. Please take note that this may be
filed in and acted upon only by the court
where the action is filed but if no action
has yet been filed, it may be filed with the
court that issued the search warrant. If no
resolution has yet been made by the
Search Warrant Court by the time an
Information is filed, then the trial court
shall resolve the Motion to Quash.
Comment [FG91]: Checklist:

1. Caption and Title
2. Distinct Specification of Factual and
Legal Grounds for Quashal
a. Failure to comply with form
prescribed by law
b. Served beyond period
c. More than one offense
d. No personal determination of probable
cause by Judge
e. No probable cause
3. Relief
4. Place/Date
7. Proof of Service

Plaintiff,
- versus -

For: Libel
VIG CHAN,
Accused.
x ----------------------------------------------x
MOTION TO SUPPRESS EVIDENCE UNLAWFULLY SEIZED
The ACCUSED, by counsel, respectfully moves for the suppression of objects seized on 23 July
2006, pursuant to Search Warrant No. 1122 issued by this Honorable Court dated 12 July 2006, based on
the following considerations:
[2] 1. Search Warrant No. 1122 was served on the 11th day and is, thus, void.
2. The motor vehicle seized does not fall within the property that may lawfully be seized.
Discussion
[1] Search Warrant No. 1122 was
served on the 11th day and is, thus,
void.
1. Rule 126, Sec. 10 of the Revised Rules of Court provides expressly that a search warrant shall
be valid for ten (10) days from its date and that thereafter, it shall be void.
2. Search Warrant No. 1122 is dated 12 July 2006. It was served on the accused on 23 July
2006, the 11th day from its date; this is certified to by the Sworn Inventory and Return executed by Major
Alang Alam, the leader of the searching team (a copy of which is already part of the records). A search
was made on the same day, 23 July 2006; pursuant to said search, certain objects were seized and
delivered to the court. Under the law, the Search Warrant is void.
3. No valid seizure may be made under a void warrant. For this reason, the following objects
must be suppressed:
[list items]
[2] The motor vehicle seized does
not fall within the property that
may lawfully be seized.
4. On the occasion of the search, the searching party also seized accuseds green Jaguar XJE
with license plate, No. 1", allegedly for being subject of the offense. Thereafter, it was impounded and
kept at the PNP Motor Pool.
5. The motor vehicle cannot be subject of the offense as accused is charged with libel. There is
no relation between the motor vehicle and libel.
6. Moreover, the motor vehicle is not mala prohibita that would justify a seizure thereof; neither
could there be a seizure of evidence in plain view.
[3] WHEREFORE, it is respectfully prayed that all objects seized under the void Search Warrant
No. 1122 be declared INADMISSIBLE under the exclusionary rule in Article III, section 3(2) in relation to
Section 2 of the 1987 Constitution. Furthermore, it is prayed that the Green Jaguar XJE with license plate
No. 1" be immediately returned to the accused.
[5] (Sgd.) MA TAPANG
Counsel for Accused
[Address]
PLUS:
39
acknowledged by the Supreme Court in

case law. Please take note that this may be
filed in and acted upon only by the court
where the action is filed but if no action
has yet been filed, it may be filed with the
court that issued the search warrant. If no
resolution has yet been made by the
Search Warrant Court by the time an
Information is filed, then the trial court
shall resolve the Motion to Quash.
Comment [FG93]: Checklist:

1. Caption and Title
2. Distinct Specification of Factual and
Legal Grounds for Suppression
a. Search without witnesses
b. Served beyond period
c. More than 1 offense
d. No receipt
e. No inventory
f. Property not subject of seizure
g. Not evidence in plain view
3. Prayer/Relief
4. Place/Date
7. Proof of Service

Plaintiff,
For: Murder
- versus -
4.
5.
6.
7.
8.
Prayer/Relief
Place/Date
Signature of Counsel
Notice of Hearing
Proof of Service
NAKA PIIT,
Accused.
x ------------------------------------------x
MOTION FOR BAIL
[2] THE ACCUSED, by counsel, respectfully moves to be allowed bail on the ground that the[3]
prosecutions evidence of his guilt is not strong. In support, he respectfully submits the following:
1. The Information alleges that he raped the private complainant on 25 December 2005 at his
residence in Quezon City. The prosecutions own evidence, however, belies this allegation as: (a) the
medical certificate (attached as ANNEX A to the Information) states that private complainant is in a virgin
state with no physical and outward signs of trauma; (b) the medical certificate issued by the NBI doctor
(attached as ANNEX B to the Information) after a physical examination of the accused, two (2) days after
the alleged rape, shows that he is suffering from erectile dysfunction and has been so afflicted for close
to five (5) years now and (c) the sworn statements of the private complainant conflict with and contradict
each other such that her credibility must be placed in doubt.
2. For these reasons, there is no basis to conclude that the accused raped the private
complainant as there is less than circumstantial evidence of this fact. He is, thus, entitled to bail as a
matter of right.
WHEREFORE, it is respectfully prayed that the accused be granted: (1) a bail hearing, during
which the prosecution should be directed to present its evidence to show the strength of its evidence of
the accuseds guilt, and (2) thereafter, grant the accused reasonable bail.
Quezon City; 7 July 2007.
[Address]
PLUS: Request for and Notice of Hearing
40
Comment [FG95]: See Rule 114, as

amended; however, as bail is generally a
matter of right and is only limited and
made discretionary in capital cases, the
allegation in this regard would invariably
be to the effect that the evidence of guilt is
not strong and the relief prayed for would
be a bail hearing and the subsequent
admission to bail.

Plaintiff,
3. Prayer/Relief
4. Verification by Applicant
- versus -
RECY DIVIST,
Accused.
x ----------------------------------------------x
APPLICATION FOR PROBATION
THE ACCUSED, by counsel, respectfully applies for probation pursuant to the provisions of
Presidential Decree No. 968, as amended.
In support of this application, the accused respectfully submits the following:
1. Accused-applicant is of legal age and currently gainfully employed at ASN Broadcasting
Corporation located at Timog Avenue, Quezon City. On 23 February 2007, she pleaded guilty to the
offense charged herein; consequently, this Honorable Court in its Order dated 8 March 2007 sentenced
accused-applicant to an indeterminate penalty ranging from three (3) years to five (5) years of prision
correccional.
[2] 2. Accused-applicant humbly submits that she possesses all the qualifications and none of
the disqualifications enumerated under section 2 of Presidential Decree No. 968, specifically:
2.1. She has not been convicted of any crime against national security or public
order;
2.2. She has not been previously convicted by final judgment of an offense
punishable by imprisonment of not less than one (1) month and one (1) day and/or a
fine of not less than Two Hundred Pesos (P200.00);
2.3. She has not previously applied for nor had been previously placed under
probation under Presidential Decree No. 968.
2.4. She has not started to serve her sentence and, to date, has not filed any
Notice of Appeal from the Order of conviction.
3 Finally, granting this application will not in any way depreciate the seriousness of the offense
charged nor cause any undue risk that during the period of probation, accused-applicant will commit
another crime. Moreover, accused-applicant does not need any correctional treatment requiring
commitment to an institution.
[3] WHEREFORE, accused-applicant respectfully prays that her application for probation be
GRANTED and that she be placed under probation under such terms and conditions necessary to attain
and ensure the objectives of the law and which, under the circumstances, are fair, just and reasonable in
the sound discretion of this Honorable Court.
Quezon City for Pasig City; 12 March 2007.
Counsel for Accused
[Address]
PLUS:
1. [4] Verification
41

Plaintiff,
- versus RECY DIVIST,
Accused.
x ------------------------------------------x
FORMAL OFFER OF EVIDENCE
THE PROSECUTION, by the undersigned public and private prosecutors, respectfully offer their
documentary exhibits in support of their case-in-chief:
1. Exhibit A, the sworn statement of Alang Kaso, the private complainant, and Exhibit A-1, his
signatureto prove that on the date and time stated in the affidavit, the accused issued a post-dated
check in the amount of One Million Pesos (P1,000,000.00) which, on presentment for payment, was
dishonored for lack of insufficient funds; to prove authorship and the authenticity of the sworn
statement; and as part of the testimony of the private complainant.
2. Exhibit B, the post-dated check dated 30 June 2004, issued by the accused in the amount of
One Million Pesos (P1,000,000.00); Exhibit B-1, the dorsal side of the check with notation DAIF; Exhibit
B-2, the signature of accused on face of the checkto prove the issuance of the check, the amount
stated, the reason for dishonor and the identity of the issuer. The marked copies of Exhibits A and B are
already part of the record.
WHEREFORE, the prosecution respectfully prays that the foregoing Exhibits be ADMITTED as
proof of the facts therein stated and in support of its case-in-chief and for all other relevant purposes.
Comment [FG97]: Variably and acceptably

denominated by others as Formal Offer of
Documentary Exhibits; please note that
this applies to criminal and civil cases. In
criminal cases, the private prosecutor has
no personality to formally offer the
evidence, thus, the offer is made in the
name of the prosecution.
Comment [FG98]: If the question calls for
an Offer of Evidence by the
Accused/Defense, then the proper 1st par.
should read: The Accused (Defendant), by
counsel, respectfully offers his/her
documentary exhibits in support of his/her
defenses, as follows:. Invariably, the Offer
of Evidence is made in table or column
form such that it would be easier for the
Court to see the Exhibit No., Description
and Purpose but, for purposes of the Bar,
this would not be practicable nor practical.
All that is important is that the Offer
contain the Exhibit Number, a description
of the Exhibit and the Purpose of Offer.

ELLIOT NESS
Public Prosecutor
ATTICUS FINCH
Private Prosecutor
Copy furnished:
MITCH MCDEERE
Counsel for Accused
42
Comment [FG99]: This is a common

mistake for any legal document submitted
by a private prosecutor. It is important to
remember that the private prosecutor has
no personality to do anything in a criminal
case as everything is under the control and
direction of the public prosecutor. Thus,
every legal document must be signed by
both the public prosecutor and the private
prosecutor. Note that it would also be
acceptable to have the Offer that is
prepared by a private prosecutor signed
by the public prosecutor to show his
conformity thereto.

- versus RECY DIVIST,
Accused.
x ------------------------------------------x
COMMENT ON THE PROSECUTIONS
FORMAL OFFER OF EVIDENCE
THE ACCUSED, by counsel, respectfully oppose the Prosecutions Offer of Evidence for the
following reasons:
1. Exhibit A, the sworn statement of Alang Kaso, the private complainant, and Exhibit A-1, his
signature are INADMISSIBLE because the private complainant was never presented to authenticate the
document or subjected to cross-examination, thus, the document is hearsay and inadmissible.
2. Exhibit B, the post-dated check dated 30 June 2004, issued by the accused in the amount of
One Million Pesos (P1,000,000.00); Exhibit B-1, the dorsal side of the check with notation DAIF; Exhibit
B-2, the signature of accused on face of the check are INADMISSIBLE for violation of the Best Evidence
Rule as the original check was never presented; and no basis for the presentation of secondary evidence
laid.
ACCORDINGLY, the ACCUSED respectfully submits that the Prosecutions Exhibits are
INADMISSIBLE and must, thus, be EXCLUDED.
[Address]
Copy furnished:
ELLIOT NESS
Public Prosecutor
ATTICUS FINCH
Private Prosecutor
43
Comment [FG100]: NOTE: The purpose of

the offer is never objected to; rather it is
the admissibility of the document that is
objected to. The purpose of offer goes to
weight of the document (unless of course,
the objection is relevance, then purpose
may properly be objected to as relevance
also determines admissibility). Any
objections to purpose should be made in
the Memorandum and an appropriate
reservation to do so may be stated in the
Comment.

Plaintiff,
For: Violation of PD 1866
- versus ANAKIN SKYWALKER,

Accused.
x ----------------------------------------x
DEMURRER TO THE PROSECUTIONS EVIDENCE
THE ACCUSED,
by counsel, it leave
of court
obtained,
previously
respectfully submits t is
Demurrer tot e Prosecutions Evidence
on t e ground t at t e prosecution
as failed to adduce sufficient

evidence of is guilt to overcome t e presumption of innocence and s ift t e burden of proof:
1. Under t e Constitution,
t e accused
is presumed to be innocen
t until
proven guilty. The effect
of t is presumption is t at it entitles t e accusedto not say anyt ing in is defense

and places t e
burden directly
on t e prosecution to prove everyt ing relative to is guilt. Thus, t e prosecution must
rely ont e strengt of its evidence and not aitfor t e accused to offer any defense. Itis only
in t e
after resting its case, as adduced sufficient evidence of guilt t at t e burden
event t att e prosecution,
of proof s ifts to t e accused.
2. The prosecution
burden of proof.
as failed to adduce sufficient evidence of guilt suc
Comment [FG101]: A Demurrer may also

be called a Motion to Acquit as the relief
sought is acquittal.
Comment [FG102]: There is a different
rule in criminal procedure as regards a
Motion for Leave to File A Demurrer. The
Motion for Leave must be filed prior to the
Demurrer. It is only when the Motion for
Leave is granted that the Demurrer may be
filed.
as ould s ift t e
2.1. Theaccused is c arged it violation of PD 1866; t e gravamen of t e

of a firearm. Concretely,
t is means t at t e
offense is unaut orized possession
prosecution must prove t at t e accused ad no legal aut ority to possess any firearm.
2.2. The prosecution

as failed to s ow t at t e accused ad no license to carry
a firearm. The proof of t e negative element is indispensable to proof of a violation of PD

1866. Wit out proof of t is negative element, t e crime is not proven.
3. Absent proof of t e negative

element, i.e., absence of a license, t e offense is not proven.
The accused is innocent; e must, t us, be acquitted.
respectfully
prays t at t e Information against im be DISMISSED and
WHEREFORE, t e accused
t at e be ACQUITTED of t e crime c arged.

DARTH SIDIOUS
Counsel for t e Accused

[Address]
Comment [FG103]: -NOTE: A Demurrer is

essentially a Motion to Acquit. It is thus a
litigious motion and should be set for
hearing.
44
ANAKIN SKYWALKER,
Plaintiff,
Defendant.
x ----------------------------------x
DEMURRER TO THE EVIDENCE
DEFENDANT, by counsel, it leave of court previously sought and ranted, respectfully submits
tis Demurrer to te Evidence because plaintiff as failed to prove entitlement to is claims by a
preponderance of evidence:
1. This action seeks to collect a sum of money arising from a contract.
2. Plaintiff, after resting is case, as failed to: (a) prove t e aut enticity of t e contract, (b) t e
extent of t e obliation under t e contract, (c) t e demandability of t e obliation under t e contract and
(d) defendants liability for te obliation and damages.
3. Consequently, plaintiff as failed to prove is claims by a preponderance of evidence and
defendant is entitled to a dismissal of te Complaint against er.
WHEREFORE, defendant respectfully prays t at t e Complaint against er be DISMISSED.
[Address]
45
Comment [FG104]: Note the difference in

the rule between a civil demurrer and a
demurrer in criminal cases insofar as
effects of leave of court is concerned. A
civil demurrer may be filed with or without
leave of court but if the demurrer is
granted and later reversed on appeal, the
defendant loses the right to adduce
evidence.

Branch 71, Antipolo
DAMI LUPA,
Plaintiff,
Civil Case No. 007
For: Reconveyance
- versus ALANG LUPA,

Defendant.
x ----------------------- x
NOTICE OF LIS PENDENS

THE REGISTER OF DEEDS
Antipolo City, Rizal Province
Please take notice that a parcel of land covered by TCT No 1234 located in Antipolo, Rizal;
registered in the name of defendant is the subject matter of an action for reconveyance of an undivided
one-sixth portion thereof filed by DAMI LUPA, above-named plaintiff. Accordingly, please record this
notice on the title.
[Address]
Copy furnished:
MITCH MCDEERE, Esq.
46

ANAKIN SKYWALKER,
Plaintiff,
Civil Case No. 1357
For: Legal Separation

Defendant.
x --------------------------------x
ENTRY OF APPEARANCE
Please enter the appearance of the undersigned as counsel for defendant Padme Amidala, with
her express conformity as indicated below, in this case. Henceforth kindly address all pertinent notices to
the undersigned at the address given below.
No. 1, Imzadi Place
Tatooine, Pasig City
WITH MY CONFORMITY:
(Sgd.) PADME AMIDALA
Comment [FG107]: This is frequently

overlooked but is actually the most
important part of the Entry of Appearance
as it indicates to the Court the authority
given and the source of such authority.
Copy furnished:
DARTH SIDIOUS
47
ANAKIN SKYWALKER,
Plaintiff,
Civil Case No. 1357

Defendant.
x --------------------------------x
WITHDRAWAL OF APPEARANCE
Please make of record the WITHDRAWAL of the undersigned as counsel for plaintiff ANAKIN
SKYWALKER, with his express conformity as indicated below, in this case. Henceforth kindly address all
pertinent notices to plaintiff at his address given in the Complaint.
(Sgd.) MACE WINDU
1 Imperial Palace, Cloud City, Pasig City
WITH MY CONFORMITY:
(Sgd.) ANAKIN SKYWALKER
2. Withdrawal as Counsel WITHOUT conformity of client

(Caption)
ANAKIN SKYWALKER,
Plaintiff,
Civil Case No. 1357

Defendant.
x --------------------------------x
WITHDRAWAL OF APPEARANCE
Please make of record the WITHDRAWAL of the undersigned as counsel for plaintiff ANAKIN
SKYWALKER due to irreconcilble professional differences ith plintiff, for ich reason the
express formity f plintiff t be btained . Henceforth kindly address all pertinent notices
to plaintiff at his address given in the Complaint.
(Sgd.) MACE WINDU
1 Imperial Palace, Cloud City, Pasig City
48
Comment [FG108]: NOTE: If the client

gives express conformity, no reason for
withdrawal needs to be given. However, if
withdrawal is without conformity, the court
may ask counsel to secure conformity. If
withdrawal is due to fundamental and
irreconcilable professional differences, then
it must be stated so that the absence of
conformity of the erstwhile client is
justified.
ANAKIN SKYWALKER,
Plaintiff,
Civil Case No. 1357

Defendant.
x --------------------------------x
SUBSTITUTION OF COUNSEL
THE UNDERSIGNED respectfully enters his appearance as counsel for defendant Padme Amidala
in substitution of former counsel Darth Maul, as shown by her express conformity below. Henceforth,
kindly address all pertinent notices to the undersigned at the address given below.
OBI WAN KENOBI
2 Corruscant Place
Tatooine Road, Pasig City
WITH MY CONFORMITY:
(Sgd.) PADME AMIDALA
G. Notice of Appeal

Branch 1, Manila
TALO NAN,
Plaintiff,
- versus PANA LO,
Defendant.
x------------------------- x
NOTICE OF APPEAL
PLAINTIFF, by counsel, respectfully appeals to the Court of Appeals the Decision of this
Honorable Court dated 6 July 2006, a copy of which he received on 16 July 2006, for being contrary to
law and the evidence presented.
Quezon City for Manila; 17 July 2006.
[Address]
Copy furnished:
MITCH MCDEERE
49
Comment [FG110]: NOTE: The Notice of

Appeal is filed with the trial court, not the
appellate court.

Branch 191, Makati
IN RE: PETITION FOR HABEAS
CORPUS OF THE MINORS LUKE
AND LEIA SKYWALKER
SP No. 111334
PADME AMIDALA,
Petitioner.
ANAKIN SKYWALKER,
Respondent.
x ------------------------------------------x
PETITION
1. Petitioner is the mother of the minors Luke and Leia Skywalker, who were born out of the
valid marriage between petitioner and respondent Anakin Skywalker.
2. The marriage failed and petitioner has been living separately from respondent since 2004.
Sometime in February 2007, respondent, unknown to petitioner, abducted the minor children and has
kept them incommunicado and out of petitioners reach.
3. Being below seven (7) years of age, custody of the minors is naturally presumed to belong to
petitioner, as their mother. Consequently, respondents refusal to allow petitioner to regain custody over
the minors is unlawful and unjustified.
WHEREFORE, petitioner respectfully prays that a writ of habeas corpus issue directing
respondent to make a return showing his legal authority to detain the minor children, subject of this
petition, and thereafter, present the minor children personally before the Court on a date and time it
chooses.
OBI WAN KENOBI
Counsel for Petitioner
[Address]
PLUS: Verification and Certification against Forum Shopping
50
SP No. 111334
DARTH VADER and PADME AMIDALA,
Petitioners.
x ------------------------------------------x
PETITION
PETITIONERS, by counsel, respectfully state that:
1. Petitioners are husband and wife, both of legal age, and residents of __________.
2. They have no legitimate children of their own and desire to jointly adopt a minor named
ANAKIN SKYWALKER, 10 years old, the legitimate child of _________________.
3. The parents of the minor are not insane, intemperate and are in full possession of civil
capacity; they have not abandoned the minor child. With full knowledge of petitioners intention, they
have expressly given their written consent to the adoption, as shown by their statement, a copy of which
is attached as ANNEX A.
4. Petitioners are qualified to adopt the minor and are financially capable of supporting the
minor; they are also morally qualified to bring up and educate the said minor.
WHEREFORE, it is respectfully prayed that judgment be rendered in petitioners favor adjudging
the minor child ANAKIN SKYWALKER freed from all legal obligations of obedience and maintenance with
respect to his/her natural parents and that he/she be declared to all legal intents and purposes, the child
of herein petitioners and that his/her surname be changed to that of petitioners.
(Sgd.) MASTER YODA
[Address]
51

1. Petitioner is a Filipino citizen, of legal age and married to respondent. For purposes of this
petition, she may be served with notices and other pertinent processes through counsel at [address of
counsel].
2. Respondent is a Filipino citizen, of legal age, currently employed at [state employer] and
married to petitioner. He may be served with summons and other pertinent orders and processes of this
Court at [state address]
2003, the ff. provisional orders may be

applied for upon filing of a petition for
declaration of nullity of marriage:
a) spousal support [ 2]
b) child support [ 3]
c) child custody [ 4]
d) visitation rights [ 5]
e) hold departure orders [ 6]
f) order of protection [ 7]
g) admin of common property [ 8]
3. Petitioner and respondent were married on [date] and out of this marriage, they have [state
number of children, respective ages]. A copy of the Marriage Contract executed by petitioner and
respondent is attached as ANNEX A; a copy each of the birth certificates of the minor children is
attached as ANNEX B, C and D, respectively.
4. Petitioner and respondent are currently separated in fact and have been so since May 2001.
The reason for the continuing separation in fact is the breakdown of the marriage due to both petitioners
and respondents mutual psychological incapacity to fulfill and discharge their respective marital
obligations to each other, which existed at the time of the marriage in 1998 but manifested itself well into
the marriage
Comment [FG113]: NOTE: It may be

psychological incapacity only on the part of
one party so the allegations may be tailored
to address that situation.
5.
The mutual psychological incapacity of the parties to remain married to each other appears
to be incurable; prior to this resort, the parties had attempted formal and informal counseling sessions all
of which proved unproductive as respondent proved resistant and, at times, even hostile to these efforts.
6. In compliance with jurisdictional requirements, petitioner submitted herself to a psychological
and clinical assessment by a trained professional, Clinical Psychologist [state name]. Despite several
attempts, respondent refuses to agree to any sober and productive discussion with petitioner and is
always highly emotional and angry, it was, thus, impracticable to secure a psychological report and
profile of respondent; should this become material, petitioner reserves the right to request respondent to
submit to a psychological examination for purposes of confirming the mutual psychological incapacity to
remain married to each other.
7.
Petitioners psychological incapacity is described in clinical terms as being consistent with a
V61.1 Partner Relational Problem and is said to have Masochistic Personality Disorder or 301.9
Personality Disorder Not Otherwise Specified; on the other hand, the assessment given by the
psychologist of respondents psychological make-up is that he has a 301.20 Schizoid Personality Disorder
with narcissistic features which is described as grave, incurable and has antecedents.
The
psychological make-up of petitioner and respondent is explained in greater detail in the Clinical
Assessment Report (Report) dated 28 December 2006, a copy of which is attached as ANNEX E.
8. Their minor children are in petitioners custody and are being supported by her financially
and emotionally.
9. Petitioner submits that, despite the parties mutual psychological incapacity to remain married
to each other, the interests of the children are best served by having them remain in her custody, with
visitation rights extended to respondent. All of the children are minors and, under the law, children under
seven (7) years of age shall not be separated from the mother, save for exceptional circumstances which
do not exist in this case.
10. Petitioner cannot, however, provide for all the financial needs of the children as she is only
earning a limited amount of money from her work whereas respondent is gainfully employed and earns
more than enough for his own personal needs. Petitioner earns only (state amount) from her work as
shown by her payslip attached as ANNEX F whereas respondent earns (state amount) from his work as
shown by his payslip attached as ANNEX G. The common property of petitioner and respondent is
insufficient for the support of the children. Respondent must, thus, be directed to give support to his
children in the amount of (state amount).
WHEREFORE, petitioner respectfully prays that PROVISIONAL ORDERS for child custody and child
support be issued giving to petitioner custody pendente lite over their minor children and directing
respondent to give monthly support in the amount of (state amount), subject to any adjustments that
may be made based on changing earning capacity as well as needs.
52
Comment [FG114]: Under the Rule on

Provisional Orders , child custody may be
sought in a petition for declaration of
nullity where the court considers the best
interests of the child as paramount;
provisional custody may be awarded to the
following based on the order of preference:
1) to both parents jointly
2) to either parent taking into account all
relevant considerations, esp. the choice of
the child
3) to the surviving grandparent, or if there
are several of them, to the grandparent
chosen by the child above 7 years of age
unless the grandparent chosen is unfit or
disqualified
4) to the eldest brother or sister over 21
years of age unless unfit or disqualified
5) to the actual custodian over 21 years of
age unless unfit or disqualified, or
6) to any other person deemed by the court
suitable to provide proper care and
guidance. 4.
Comment [FG115]: Under the Rule on
Provisional Orders , child support may
also be sought. It must first be taken from
the properties of the absolute community
or the conjugal partnership. In the
discretion of the court, either parent or
both may be ordered to give an amount
necessary for support, maintenance and
education of the child in proportion to the
resources or means of the giver and to the
needs of the recipient. Thus, the earning
capacity of the parent and the amount
needed for support must be alleged.
[1] Declaring the marriage between petitioner and respondent a nullity and, by this
token, ordering the dissolution of the conjugal partnership of gains; and
[2] Awarding permanent custody of the children to petitioner, with express
acknowledgement of respondents visitation rights;
[3] Awarding support in the amount of (state amount) subject to adjustments to be
made depending on changes in earning capacity and needs of the children.
All other just and equitable reliefs are also prayed for.
[Address]
53

Branch 30, San Juan
RE: PROBATE OF THE HOLOGRAPHIC
WILL OF PABLING SIA.,
SP PROC. No. 0023
PALING KERA,
Petitioner,
x ------------------------------------x
PETITION
1. Petitioner is a Filipino citizen and the widow of the deceased.
2. On 16 August 2006, PABLING SIA died, having previously executed a holographic will in his
own handwriting and in a language known to him. A copy of the will is attached as ANNEX A. The
handwriting may be attested to as his by his secretary of long standing, TOM CRUZ.
2. The deceased left a house and lot located at No. 555, Tuna Road, Marinara Subdivision,
Quezon City and cash amounting to Fifty Thousand Pesos (P50,000); he had no debts.
3. The deceaseds only heirs are herein petitioner and their son, PABLING SIA JR., both of whom
are residing at No. 555, Tuna Road, Marinara Subdivision, Quezon City.
WHEREFORE, it is respectfully prayed that after due notice and publication this Honorable Court
fix the date for the probate of the holographic will and that letters of administration be issued in favor of
the herein petitioner and thereafter adjudicate the properties of the deceased in accordance with the said
holographic will.
[Address]
54
KNOW ALL MEN BY THESE PRESENTS:

I, OBI WAN KENOBI, of legal age, and resident of Tatooine, do hereby name, constitute and
appoint PADME AMIDALA, of legal age, and resident of Naboo, to be my true and lawful Attorney-in-Fact
and in my name, place and stead, do perform the following specific act(s):
(Specify the particular act/s to be performed)
Giving and granting unto said attorney-in-fact power and authority to do every act necessary and
required in connection with these presents, and hereby ratifying and confirming all that she may do by
virtue of these presents.
IN WITNESS WHEREOF, I have signed this Special Power of Attorney this 7 July 2007 at
Tatooine.
Principal
SIGNED IN THE PRESENCE OF:
(Sgd.) R2D2
(Sgd.) C3PO
Acknowledgment
B. General Power of Attorney

GENERAL POWER OF ATTORNEY
I, OBI WAN KENOBI, of legal age, and resident of Tatooine, do hereby name, constitute and
appoint PADME AMIDALA to be my true and lawful attorney-in-fact, for me and in my name, place and
stead, to do and perform the following acts, to wit:
(Specify general acts that Attorney-in-Fact may do)
Giving and granting unto my said Attorney-in-Fact full power and authority necessary and
required to carry out the acts as fully to all intents and purposes as I might do or lawfully do if personally
present, with power of substitution and revocation, and hereby ratifying and confirming all that my said
attorney-in-fact or his substitute shall lawfully do or cause to be done under and by virtue of these
presents.
IN WITNESS WHEREOF, I have signed this instrument this 7 July 2007 at Tatooine.
Principal
(Sgd.) R2D2
(Sgd.) C3PO
Acknowledgment
55

This Agreement made and entered into at Makati this 7th day of July 2007 by and between DAMI
BAHAY, of legal age, married to ASA WA, (LESSOR) and resident of Makati City, and ALANG BAHAY, of
legal age, single and resident of Quezon City (LESSEE), WITNESSETH that:
1. In consideration of a monthly rental of FIVE THOUSAND PESOS (P5,000.00) and the
covenants made below, the LESSOR hereby LEASES to the LESSEE an apartment located at 199 San
Antonio Village, Makati City covered by Tax Declaration No. 001 (Makati City Assessors Office) for a
period of TWELVE (12) MONTHS from signing of this contract.
2. The LESSEE covenants, as follows:
2.1. To pay the rentals on or before the fifth day of each month, without need
of demand at the residence of LESSOR;
2.2. To keep the premises in good and habitable condition, making the
necessary repairs and painting inside and outside the house;
2.3. Not to make major alterations and improvements without the written
consent of the LESSOR and in the event of such unauthorized major alterations and
improvements, surrendering ownership over such improvements and alterations to the
LESSOR upon expiration of this lease;
IN WITNESS WHEREOF, the parties have signed this contract on the date and the place first
mentioned.
DAMI BAHAY
Lessor
ANG BAHAY
Lessee
With my consent:
ASA WA
Acknowledgment
BEFORE ME, a Notary Public for Makati City, personally appeared on the 7th of July 2007, the
following persons, with their respective CTC details indicated below:
DAMI BAHAY
ALANG BAHAY
CTC No. ____________ issued at/on

CTC No. ____________ issued at/on
known to me to be the same persons who executed the foregoing instrument, denominated as a Contract
of Lease consisting of __ pages, signed on each and every page by the parties and their instrumental
witnesses, having acknowledged the same before me as their own free and voluntary act and deed.
TO THE TRUTH OF THE FOREGOING, witness now my hand and seal on the date and place
mentioned above.
N.O. TARIO
Until December 31, 2007
PTR No. 0000111/1/05/99, Makati City
Doc. No.
Page No.
Book No.
Series of 2007.
56
I hereby execute this holographic will, in my handwriting and in the English language which I
know how to read and write, bequeathing my house and lot located at No. 555, Tuna Road, Marinara
Subdivision, Quezon City to my son, PABLING SIA JR., and cash amounting to Fifty Thousand Pesos
(P50,000) to my spouse, PALING KERA.
(Sgd.) PABLING SIA SR.
E. Notarial Will
Comment [FG120]: 1979, 1983 and 2004

Bar Exams
LAST WILL AND TESTAMENT

of
PABLING SIA, SR.
I, PABLING SIA, SR., of legal age, married to PALING KERA, a native of Lipa City, Batangas, now
actually residing at San Juan, Metro Manila, being of sound and disposing mind and memory, and not
acting under influence, violence, fraud or intimidation of whatever kind, declare this to be my Last Will
and Testament which I have caused to be written in English, the language which is known to me. And I
hereby declare that:
I.
The following are my children and their addresses;

(Name of children and addresses)
II.
I give and bequeath to my children __________, __________, and __________,

in equal shares, the following properties, real and personal, whatsoever and
wheresoever located:
(Description of property)
III.
I designate _______________ as the sole executor of this Last Will and

Testament.
IN WITNESS WHEREOF, I have set my hand this 7th day of July 2007 in San Juan, Metro Manila.
(Sgd.) PABLING SIA, SR.
57
WE, the undersigned witnesses, whose residences are stated opposite our respective names, do
hereby certify that: the testator _________________ has published unto us the foregoing will consisting
of ___ pages numbered correlatively in letters on the upper part of each page, as his/her last will and
testament and has signed the same and every page thereof, on the left margin, in our joint presence and
we, in turn, at his/her request have witnessed and signed the same and every page thereof, on the left
margin, in the presence of the testator and in the presence of each other.
SAKSI 1
SAKSI 2
SAKSI 3
Residence
Residence
Residence
Comment [FG122]: There must be at least

3 instrumental witnesses.
G. Acknowledgment of a Notarial Will

JOINT ACKNOWLEDGMENT
BEFORE ME, Notary Public for and I the City of San Juan, Philippines, this 7th day of July, 2007,
personally appeared:
PABLING SIA, SR. (Testator), with Valid Identification Document _______ issued by
(official agency), on 6 July 2006;
SAKSI 1 (Witness), with Valid Identification Document _______ issued by (official
agency), on 6 July 2006;
all known to me to be the same persons who signed the foregoing Will, the first as testator and the last
three as instrumental witnesses, and they respectively acknowledged to me that they signed the same as
their own free act and deed.
This Will consists of ___ pages, including the page in which this acknowledgmentis written, and
has been signed on the left margin of each and every page thereof by the testator and his witnesses and
has been sealed with my Notarial seal.
IN WITNESS WHEREOF, I have set my hand the day, year and place written.
(Sgd.) N. O. TARIO
Notary Public
Until __________________
PTR No. _______________
Issued at ______________
On ___________________
Doc. No.
Page No.
Book No.
Series of 2007.
58

This Deed of Donation, made and executed by LALIM BULSA, of legal age, single/married, and
resident of _______________ (Donor) in favor of DAMI UTANG, of legal age, single/married and
resident of _________________ (DONEE) WITNESSETH:
That the DONOR is the owner of that certain real property with the buildings and improvements
thereon, situated in _________________, and more particularly described in Original/Transfer Certificate
of Title No. ____ of the land registry of _____________, as follows:
(Copy description of property in title)
That for and in consideration of the love and affection which the DONOR has for the DONEE, the
said DONOR, by these presents, transfers and conveys, by way of donation, unto said DONEE, his/her
heirs and assigns, the above described real property with all the buildings and improvements thereon,
free from all liens and encumbrances;
That the DONOR does hereby state, for the purpose of giving full effect to this donation, that
he/she has reserved for himself/herself in full ownership sufficient property to support him/her in a
manner appropriate to his/her needs;
That the DONEE does hereby accept this donation of the above-described property, and does
hereby express gratitude for the kindness and liberality of the DONOR.
IN WITNESS WHEREOF, the DONOR and the DONEE have signed this deed on 7 July 2007 and at
Quezon City, Philippines.
LALIM BULSA
Donor
ACCEPTED:
DAMI UTANG
Donee
(Sgd.) MIRON 1
(Sgd.)MIRON 2
PLUS: Acknowledgment
59
I, GEORDI LA FORGE, (Nominee), of legal age, and with office address at __________, hereby
acknowledge my status as nominee for WILLIAM RIKER (the Principal) for the purpose of holding title
to ___ shares of stock in the Enterprise Holdings Inc. (the Corporation). As nominee, I hereby
unequivocally confirm that the Principal is the exclusive and absolute owner of the subject shares.
Accordingly, the relationship between the principal and the nominee with respect to the subject shares is
governed by the following terms and conditions:
1. All dividends, whether cash, stock or property, rights and other privileges, accruing
on the subject share shall be for the account and benefit of the principal; accordingly,
the nominee shall deliver the same to the principal and whoever the latter may
designate.
2. Directors fees and other amounts received by way of compensation for services
rendered by the nominee shall be for the account and benefit of the nominee.
3. The principal shall save the nominee free and harmless from any liability, whether for
unpaid subscriptions, taxes or otherwise, that may arise as a result of the nominees
holding title to the subject shares for and on behalf of the principal.
4. The nominee hereby assigns, transfers, and conveys the subject shares to the
principal free from all liens and encumbrances and hereby undertakes to execute the
necessary instruments to transfer title over the subject shares to the principal or to
whoever the latter may designate.
5. This acknowledgment of nominee status shall bind the nominees heirs, executors,
administrators and other successors-in-interest.
Done this 7th day of July 2007 at Quezon City.
GEORDI LA FORGE
Nominee
WITH MY CONFORMITY:
WILLIAM RIKER
Principal
WITNESSES:
(Sgd.) UZI 1
(Sgd.) UZI 2
60
I, DEANNA TROI, of legal age, with office address at __________________, on the basis of the
corporate records, do hereby certify that under oath that:
1. I am the Corporate Secretary of ENTERPRISE HOLDINGS INC. (corporation), a corporation
duly organized and existing under Philippine laws, with the same office address given above.
2. At a meeting of the Board of Directors of the corporation held on ___________, at which
meeting a quorum was present and obtained throughout, the following resolution(s) was (were)
unanimously approved and adopted:
Comment [FG123]: Sometimes, it may be

necessary to specify whether the meeting
was a special or general meeting.
RESOLVED, that ...................

3. The foregoing resolution has not been revoked, amended or in any manner modified and
accordingly, the same may be relied upon until a written notice to the contrary is issued by the
corporation.
IN WITNESS WHEREOF, I have set my hand to this certification on ____ at ______________.
DEANNA TROI
Corporate Secretary
ATTESTED:
JEAN-LUC PICARD
President
PLUS: Jurat
K. Board Resolutions
1. Authority to Act
Board Resolution No. ___
RESOLVED, that Mr. Jean-Luc Picard, as Chairperson and Chief Executive Officer
of Enterprise Holdings be authorized, as he is hereby authorized, to enter into any and
all transactions with the representatives of the Ferengi Trade Federation, as may prove
to be beneficial to the corporation in his own opinion and determination.
Approved and adopted this 7th day of July, 2007 at Makati City, Philippines.
(Name of Directors)
2. Increase in number of directors and necessary amendment to the Articles of
Incorporation
Board Resolution No. ___
RESOLVED, by a vote of stockholders representing more than 2/3 of the
subscribed and paid up capital stock, to INCREASE the number of Directors of the
Corporation from five (5) to seven (7) and to AMEND the Articles of Incorporation to
reflect this increase.
Approved and adopted this 7th day of July, 2007 at Makati City, Philippines.
(Name of Directors)
61

I, DAMI SHARES, of legal age, Filipino and resident of ________________, for and in
consideration of the sum of ____________________ Pesos (P_____), receipt of which is hereby
acknowledged do hereby assign, cede, transfer and convey unto DAMI LUPA, likewise of legal age, and
resident of ______________, all his/her rights, title, ownership and interest over its subscription to One
Hundred Thousand (100,000) shares of the capital stock of _________ Corporation, including advances
due from said corporation. It is, however, understood that the assignee shall assume any and all unpaid
subscription on the said shares.
The assignor hereby irrevocably constitute, name and appoint the assignee to be his/her true and
lawful attorney-in-fact to make representations with the corporate secretary and to cause the annotation
of this assignment in the books of the corporation.
IN WITNESS WHEREOF, the assignor has signed this deed on 7th day of July, 2007 at the City of
Manila.
DAMI SHARES
Assignor
(Sgd.) MIRON 1
(Sgd.) MIRON 2
62
DEED OF ABSOLUTE SALE

I, MA YA MAN, Filipino, single, and resident of _________________________, for and in
consideration of the amount of _______________________, paid to me today by MA GU LANG, Filipino,
single and resident of ________________ do hereby SELL, TRANSFER and CONVEY absolute and
unconditionally unto said MA GU LANG that certain parcel(s) of land, together with the buildings and
improvements thereon situated in the City of Makati, and more particularly described as follows:
(Technical Description of property/ies; specify metes and bounds of the
property/ies with approximate area thereof, as indicated on the face of the title)
of which I am the registered owner in fee simple, my title thereto being evidenced by Transfer (or
Original) Certificate of Title No. ______, issued by the Register of Deeds of Makati City.
It is hereby mutually agreed that the vendee shall bear all expenses for the execution and
registration of this deed of sale.
IN WITNESS WHEREOF, I have signed this deed this 7th day of July, 2007 at Makati City.
MA YA MAN
Vendor
[Note: if vendor is married, marital consent must be secured; thus, the Deed must also indicate this. If
vendor is married, then add the following:]
With my consent:
ASA WA
Vendors Wife
(Sgd.) MIRON 1
(Sgd.) MIRON 2
63
DEED OF ABSOLUTE SALE

I, MA YA MAN, Filipino, single, and resident of _________________________, for and in
consideration of the amount of __________, paid to me today by MA GU LANG, Filipino, single and
resident of _______________________ do hereby SELL, TRANSFER and CONVEY absolutely and
unconditionally unto said MA GU LANG that certain parcel(s) of land, together with the buildings and
improvements thereon situated in the City of Makati, and more particularly described as follows:
(Description: state the nature of each piece of land and its improvements, situations and
boundaries, area in square meters, whether or not the boundaries are visible on the land
by means of monuments or otherwise; and if they are, what they consist of, the
permanent improvements, if any, the page number of the assessment of each property
for current year or years when registration is made, the assessed value of the property
for the year)
It is hereby declared that the boundaries of the foregoing land are visible by means of
_______________; that the permanent improvements existing thereon consist of _________ (if none,
state so); that the land is assessed for the current year at P______________ as per Tax Declaration No.
__________, and the buildings and/or improvements , at P____________ as per Tax Declaration No.
_________, of the City Assessor of Makati.
The above described real estate, not having been registered under Act No. 496 nor under the
Spanish Mortgage Law, the parties hereto have agreed to register this instrument under the provisions of
Sec. 194 of the Revised Administrative Code, as amended.
MA YA MAN
Vendor
With my consent:
ASA WA
Vendors Wife
(Sgd.) MIRON 1
(Sgd.) MIRON 2
64
DEED OF SALE WITH PACTO DE RETRO

This Deed of Sale with Pacto de Retro made and executed by and between:
MA YA MAN, Filipino, of legal age, married to ASA WA, with residence at
___________________ (VENDOR),
- and MA GU LANG, Filipino, of legal age, married to BA TAPA, with residence
at ____________ (VENDEE);
WITNESSETH: That
The VENDOR is the absolute owner of a certain parcel of land with all the buildings and
improvements thereon, situated in the City of Makati, and more particularly described, as follows:
(Copy technical description in TCT/OCT)
his title thereto shown by Transfer (or Original) Certificate of Title No. ______ issued by the Register of
Deeds of Makati;
The VENDOR, for and in consideration of the amount of _________________ Pesos (P_____), to
him paid by VENDEE and receipt of which is acknowledged, does hereby SELL, TRANSFER and CONVEY
under pacto de retro unto the said VENDEE, his heirs and assigns, the property with all the buildings and
improvements thereon, free from all liens and encumbrances whatsoever;
The VENDOR, in executing this conveyance, hereby reserves the right to REPURCHASE, and the
VENDEE, in accepting the same, hereby obligates himself to RESELL the property herein conveyed within
a period of ____ years from date of this deed for the same price of ______________ (P____); Provided,
however, that if the VENDOR shall fail to exercise his right to repurchase as herein granted within the
period provided, then this conveyance shall become absolute and irrevocable, without need of a new
Deed of Absolute Sale, subject to the requirements of law regarding consolidation of ownership of real
property.
MA YA MAN
Vendor
MA GU LANG
Vendee
With my marital consent:

ASA WA

BA TAPA

(Sgd.) MIRON 1
(Sgd.) MIRON 2
65
DEED OF RESALE
I, MA GU LANG, Filipino, married, of legal age, and resident of _______________, for and in
consideration of _______________ Pesos (P____), to me paid by MA YA MAN, Filipino, of legal age,
married and resident of ___________________, do hereby RESELL, RETRANSFER and RECONVEY unto
said MA YA MAN that certain parcel of land, with all the buildings and improvements thereon, situated at
Makati City, and more particularly described, as follows:
(Copy technical description in title)
covered by Transfer (or Original) Certificate of Title No. ____ of the Registry of Deeds of Makati, and
which property was previously sold to under pacto de retro by the said MA YA MAN on _____________,
executed before Notary Public __________ and bearing Notarial Registration No. ___, Page No. ____,
Book No. ____ and Series of 20__ of his Notarial Register, a copy of which is attached as ANNEX A.
IN WITNESS WHEREOF, I have signed this deed this 7th of July, 2007 at Makati City.
MA GU LANG
Vendor
With my consent:
BA TAPA
Vendors Wife
(Sgd.) MIRON 1
(Sgd.) MIRON 2
66
DEED OF SALE WITH MORTGAGE

This Deed of Sale with Pacto de Retro made and executed by and between:
MA YA MAN, Filipino, of legal age, married to ASA WA, with residence at
___________________ (VENDOR-MORTGAGEE),
- and MA GU LANG, Filipino, of legal age, married to BA TAPA, with residence
at ____________ (VENDEE-MORTGAGOR);
WITNESSETH: That
The VENDOR-MORTGAGEE is the absolute owner of a certain parcel of land with all the buildings
and improvements thereon, situated in the City of Makati, and more particularly described, as follows:
(Copy technical description in TCT/OCT)
his title thereto shown by Transfer (or Original) Certificate of Title No. ______ issued by the Register of
Deeds of Makati;
The VENDOR, for and in consideration of the amount of _________________ Pesos (P_____), to
him paid by VENDEE and receipt of which is acknowledged, does hereby SELL, TRANSFER and CONVEY
unto the said VENDEE, his heirs and assigns, the property with all the buildings and improvements
thereon, free from all liens and encumbrances whatsoever;
It is hereby agreed and stipulated that the UNPAID BALANCE OF ____________ Pesos (P____),
of which amount _________________Pesos (P_____) shall be paid by the VENDEE-MORTGAGOR to the
VENDOR-MORTGAGEE at the latters residence, as follows:
(State manner of payment)
In order to guarantee the fulfillment of the above obligations, the VENDEE-MORTGAGOR does
hereby MORTGAGE unto the said VENDOR-MORTGAGEE, his heirs and assigns, the property described,
together with all the buildings and improvements thereon, under the express stipulation that if the said
VENDEE-MORTGAGOR shall pay or cause to be paid unto the VENDOR-MORTGAGEE the obligations, then
this Mortgage shall be of no further force and effect; otherwise, the same shall remain in full force and
effect and shall be enforceable in the manner prescribed by law.
MA YA MAN
Vendor
MA GU LANG
Vendee
With my consent:
ASA WA
Vendors Wife
With my consent:
BA TAPA
Vendees Wife

(Sgd.) MIRON 1
(Sgd.) MIRON 2
67

This Deed of Assignment, made and executed by and between DAMI UTANG, Filipino, of legal
age, married to ALANG MALAY, with residence at _____________ (ASSIGNOR) and DAMI LUPA, Filipino,
of legal age, married to BIL MOKO, with residence at _______________ (ASSIGNEE), WITNESSETH:
That the ASSIGNOR is indebted to the ASSIGNEE in the sum of ___________ Pesos (P______)
and in full payment and complete satisfaction thereof hereby assign, transfer and convey unto the
ASSIGNEE that certain real estate with all the buildings and improvements thereon, situated in
___________, and more particularly described as follows:
(Description of property assigned)
of which real estate the ASSIGNOR is the registered owner, his title thereto being evidenced by Transfer
(or Original) Certificate of Title No. ____________ of the Register of Deeds of _____________.
That the ASSIGNEE does hereby accept this assignment in full payment of the above-mentioned
debt of ______________ Pesos (P_________).
IN WITNESS WHEREOF, the parties have signed this Deed on 7 July 2007 at Makati City.
DAMI LUPA
Assignee
DAMI UTANG
Assignor
ALANG MALAY
Assignors Wife
BIL MOKO
Assignees Wife
68
CHATTEL MORTGAGE
That I, DAMI KOTSE, of legal age, married and resident of Makati, for and in consideration of the
loan of FIVE HUNDRED THOUSAND PESOS (P500,000.00), granted to me by YAMAN NYA, also of legal
age, married and resident of Makati, to be paid one (1) year from date hereof, have transferred and
conveyed by way of chattel mortgage unto said YAMAN NYA, his heirs, successors and assigns, free from
all liens and encumbrances that certain motor vehicle, at present in my possession at my address, more
particularly described as:
: BMW 738i (1998), racing green;
: 00000001111;
: 00000001111;
Model/Make No./Color
Chassis No.
Engine No.
of which I am the true and absolute owner by title thereto, being evidenced by Registration Certificate of
Motor Vehicle No. ______ issued in my name by the Land Transportation Office on
__________________.
This chattel mortgage has been executed in order to secure the full and faithful payment of my
obligation to YAMAN NYA in accordance with the terms and conditions of this instrument; Upon payment,
this contract shall become null and void; otherwise, it shall continue in full force and effect and may be
foreclosed in accordance with law.
IN WITNESS WHEREOF, I have signed this instrument on 7 July 2007 at Makati City.
DAMI KOTSE
Affidavit of Good Faith
Comment [FG127]: Please attach this

particularly to a chattel mortgage.
We severally swear that DAMI KOTSE, mortgagor, and YAMAN NYA, mortgagee, have executed
the foregoing Chattel Mortgage in order to guarantee as good and binding the obligations mentioned
above and is not intended to defraud creditors.
YAMAN NYA
DAMI KOTSE
Signed in the presence of:
UZI 1
UZI 2
69
a. from MTC (in original jurisdiction) to RTC (in appellate jurisdiction)

Checklist:
y 15 days from notice of judgment or final order
y Notice of Appeal (Rule 40, Sec. 3)
o Parties
o Judgment or final order appealed from
o Material dates showing timeliness of appeal
y Proof of payment of appellate court docket and other lawful fees (Rule 40, Sec. 4)
y Memorandum for Appellant and Appellee (Rule 40, Sec. 7)
Comment [FG129]: Rule 40
b. From RTC (in original jurisdiction) to CA

Checklist:
y Notice of Appeal
y Brief for Appellant
o Subject Index of the matter in brief
o Assignment of Errors
o Statement of the Case
o Statement of the Facts
o Statement of the Issues
o Argument
o Relief
o Copy of judgment or final order appealed from
y Brief for Appellee (same as Brief for Appellant, except copy of judgment)
y Appellants Reply Brief
y Memorandum (in special cases)
o Statement of the Case
o Statement of the Facts
o Statement of the Issues
o Argument
o Relief
Comment [FG130]: Rule 41
2. in criminal cases
a. From MTC (as trial court) to RTC (in appellate jurisdiction)
Checklist:
y Notice of Appeal
y Appellants Brief/Memorandum
y Appellees Brief/Memorandum
Comment [FG131]: Rule 122, sec. 1(a)
b. From RTC (as trial court) to CA

Checklist:
y Notice of Appeal
Comment [FG132]: Rule 122, sec. 1(b),

sec. 3(a)
c. From RTC (as trial court) to SC

Checklist:
y Notice of Appeal
Comment [FG133]: Rule 122, sec. 3(c); the

ONLY instance when an ordinary appeal
from the RTC is with the Supreme Court
and where resort is made by simple notice
of appeal; the only ground is where the
penalty imposed is reclusion perpetua or
life imprisonment or where a lesser penalty
is imposed but involving offenses
committed on the same occasion or arising
out of the same occurrence that gave rise
to the more serious offense for which the
penalty of death or life
imprisonment/reclusion perpetua is
imposed.
70
extension of 15 days only

Full names of petitioner and respondent
Statement of Material Dates
Statement of Material Averments
Statement of Issues, Errors of Fact or Law
Argument
Verification and Certification against Forum Shopping
Attachments
o Certified true copy or duplicate original copy of judgment/final order questioned
o Clear and legible copy of all pleadings and other material portions of the record
y Proof of Service and Explanation for Service by Registered Mail (if applicable)
Comment [FG136]: Rule 42, sec. 1; Rule

43, sec. 4
2. From RTC (on pure questions of law) or CA (in appellate jurisdiction) to SC

Checklist:
y extension of 30 days
y Names of petitioner and respondent ( itout impleading te lower court/judge/justice)
y Statement of Material Dates
y Material Allegations, Reasons or Arguments for allowance of petition
y Verification and Certification against Forum Shopping
y Attachments
o Certified true copy or duplicate original copy of judgment/final order questioned
o Clear and legible copy of all pleadings and other material portions of the record
y Proof of Service and Explanation for Service by Registered Mail (if applicable)
Comment [FG138]: See also Rule 122, sec.

1(b); Rule 45, sec. 4
y
y
y
y
y
y
y
y
71
Comment [FG137]: Rule 13, section 13
Comment [FG139]: Rule 45, sec. 2
Comment [FG140]: Rule 13, section 13
[A] CAPTION AND TITLE

(COURT)
(Location)
Name of Aggrieved Party or
Relator,
Petitioner,
(Case No. _____________)
- versus -
Name of Public Official/Employee

Or Private Individual or Entity,
Respondent/s.
X ----------------------------------------X
PETITION

[B] PARTIES
1. Petitioner/Relator is . . .
1.1.
relator to victim)
1.2.
Security of Person or
1.3.
1.4.
Personal/Professional Circumstances Relevant (if by Relator, state relationship of

Factual Statements Relevant to Grounds (Violation of Right to Life, Liberty and
Threat thereof)
Contact Details
Other Relevant Details
2. Respondent/s is/are . . .
2.1. Personal/Professional Circumstances Relevant
2.2. Contact Details
2.3. Other Relevant Details
[C] BODY
3. Statement of Facts
3.1. Chronology of Events Relevant to the right violated (e.g., enforced disappearance or
extrajudicial killing)
3.2. Statement as to Judicial Affidavits (if any) of witnesses
3.3. Statement as to efforts exerted to vindicate the right/s and results of such efforts
4. Statement of Material Facts Relevant to Interim Reliefs (if any)
a.
b.
c.
d.
Temporary Protection Order

Inspection Order
Production Order
Witness Protection Order
5. Statement of Material Facts Relevant to Final Relief/s

[D]
RELIEF
( ec. 1, mparo). It is
T I
ororentity
violations or threatened violations o the right to
property per se, except here the right to property is

connected to the right to liberty such that the latter
right cannot be vindicated

ithout addressing the
threat to or violation o the right to property.
Comment
mparo may be iled ith:
[LR142]:
1. ny T o the place here
the threat or
violations happened or any o its elements
2.
3.
or
4. or ith
any o the Justices o the ,
( ec. 3, mparo)
Comment [LR143]: The petition may be iled

by:
T , or
1.
The I
2. ny Q
I I
or TIT in the .
(elators):
a. Immediate amily member, namely:

(1) pouse
(2) hildren or
(3)
arents
b. scendant, descendant, or collateral
relative o
ithin the 4th civil degree o consanguinity
the
or
a inity, in de ault
o (a)

c. In de ault o (a) and (b), any o the :
(1) concerned citizen
(2) concerned organization or association
(3) concerned institution ( ec. 2, mparo)
* iling by
precludes the iling by any o the
other entities or
the iling by an authorized
persons;
suspends
the right o all

party on behal o the
others (Id.)

While not provided expressly, i the etition is
*iled
the relators, a statement must be
by any o
that the
did not, or could not ile the
made
etition.
[LR144]: The etition must allege the

Comment
:
1. ersonal circumstances o petitioner and
respondent/s

2.The right sub ect o the etition and the act/s
allegedly
violative
o
said right/s
names,
3. ny investigation conducted speci ying
personal circumstances and addresses o the

investigating authority or individuals as ell as the
and conduct o the investigation, together
manner
ith any report
... [1]
[LR145]:
Comment
Sec. 14, mparo provides
or our interim relie s that may be iled by

veriied
motion or
given motu propio. These are T , I ,
and W .
Comment [LR146]: acts that must be stated

here must pertain
to
the
need
to protect petitioner, i
or immediate amily
s/he is the
members, in an
accredited
private institution or government agency.
(Sec. 14a, mparo)
Comment [LR147]: ourt may order any person

in possession or control o a designated land
or other
property to permit entry or the purpose o
inspection, measurement, or photographing o the
property or any relevant
ob ect or operation thereon.
The application o I must state in detail the
place/s
to be inspected and
must be supported by a idavits
or testimonies o itnesses having personal ... [2]

Comment[LR148]: PO may require any person
o accounts
in custody
o documents, papers, books
or ob ects in digitized or electronic orm hich

constitute evidence relevant to the petition or return
to produce and permit the inspection,
copying or

photographing by or on behal o the movant. (Sec.
14c, mparo)
Similar
to
an
IO,
the
PO
may also be
availed o by the respondent (Sec. 15, mparo)
Comment [LR149]: WPO may re er itnesses to

the WPP or to other government agencies or to
accredited persons or private institutions. (Sec. 14d,
mparo)
WHEREFORE, . . .
(a) Interim Reliefs be granted immediately
(b) Final Reliefs be granted after hearing
Comment [LR150]:
ote that the ule does not
expressly say hat inal relie the ourt may grant.
72
[F] Name and Signature + All Material Information of Counsel

[G] VCFS
Comment
[LR151]: The Petition must
be signed
and veri ied by

the petitioner, hether the P or
relator (Sec. 5, mparo)
[H] Affidavit of Service and Explanation of Service
The ule
does not expressly require a ertiication
against orum Shopping and a Petition or mparo
OT be dismissed or
lack o such a

certi ication ; note that a T on any ground is a
prohibitedpleading
under the ule. (Sec. 11,
mparo) o ever, ule 7, sec. 5, hich is the

general rule on all initiatory pleadings,
may already
be incorporated in the standard ormat. (See sec. 11
or Prohibited Pleadings under mparo).
73
individual or entity (Sec. 1,

(COURT)
(Location)
).
or violations or threatened
It is OT I
violations o the right to property per se, except
here the right to property is connected to the right

to liberty such that the latter right cannot be
vindicated ithout addressing the threat to or
violation o the right to property.
Name of Aggrieved Party or

Relator,
Petitioner,
(Case No. _____________)
- versus -
Comment
[LR153]:
may be iled ith:

1. ny T o the place here
the threat or
violations happened or any o its elements

2.
SB
3.
4. SC or ith any o the Justices o the SB, CA or
SC, where the actio co cer

s p blic data files of
gover me t offices (Sec. 3,
)
* There is no de inition o
is open to interpretation.
Name of Public Official/Employee

Or Private Individual or Entity,
Respondent/s.
public data iles so this
X ----------------------------------------X
PETITION

[B] PARTIES
Comment [LR154]: The petition may be iled

by:
1. The AGGRI
PART , or
2. Any Q ALI I
PERSON or ENTIT in the .
ORDER ( Relators):
a. Immediate amily member, namely:

(1) Spouse
(2) Children or
(3) Parents
b. Ascendant, descendant, or collateral

relative o
the
AP ithin the 4th civil degree o consanguinity or
a inity, in de ault
o (a)
c. In de ault o (a) and (b), any o the :

(1) concerned citizen
(2) concerned organization or association
(3) concerned institution (Sec. 2, Amparo)
1. Petitioner/Relator is . . .
1.1.
relator to victim)
1.2.
or Security or Threat
1.3.
1.4.
Personal/Professional Circumstances Relevant (if by Relator, state relationship of
* iling by AP precludes the iling by any o the

other entities or
persons; the iling by an authorized

party on behal o the AP suspends the right o all

others (Id.)
Factual Statements Relevant to Grounds (Violation of Right to Privacy in Life, Liberty

thereof)
Contact Details
Other Relevant Details
2. Respondent/s is/are . . .
2.1. Personal/Professional Circumstances Relevant
2.2. Contact Details
2.3. Other Relevant Details
* While not provided

expressly, i the Petition is
iled by any o the relators, a statement must be

made that the AP did not, or could not ile the
Petition.
Comment [LR155]: Private individuals/entities
in the
may be impleaded i these are engaged
gathering,
collecting or storing o data or
that
media
may
also
be
in ormation. Note
considered part o the private entities or individuals
ho may be impleaded as respondents.

Comment [LR156]: The Petition must allege the
:
1. Personal circumstances o petitioner and

respondent/s
2.The right sub ect o the Petition and the act/s

allegedly violative o said right/s
names,
3. Any investigation conducted speci ying
personal circumstances and addresses o the
investigating authority or individuals as ell as the

manner and conduct o the investigation, together
ith any report

4. Actions and recourses taken by petitioner
to
determine the ate and hereabouts o the AP and

the identity o persons responsible or the threat or
violation
[C] BODY
3. Statement of Facts
3.1. Chronology of Events Relevant to the right violated (e.g., enforced disappearance or
extrajudicial killing)
3.2. Statement as to Judicial Affidavits (if any) of witnesses
3.3. Statement as to efforts exerted to vindicate the right/s and results of such efforts
4. Statement of Material Facts Relevant to any Interim Reliefs (if any)
5. Statement of Material Facts Relevant to Final Relief/s
[D]
RELIEF
Comment[LR158]: nlike
Amparo, no speci ic
interim relie s are

provided in D. Suppletorily, the
interim
relie
s
o
TRO
or
In
unction
may be availed
o.
WHEREFORE, . . .
(a)
(b)
(c)
(d)
Comment [LR157]: Note that a PRIOR
DEMAND
LETTER on the
respondents or the
in ormation is required be ore the petition is iled.
This must be alleged and attached as part o the

Petition.
Interim Reliefs be granted immediately

Final Reliefs be granted after hearing
Interim Reliefs be made permanent
Other Reliefs be granted
Comment
[LR159]:
The Court may order, by
ay o inal relie that the act be en oined or the data

or in ormation deleted, destroyed or recti ied. The
Court may also order that all other relevant relie s be

granted.
74
[G] VCFS
Comment
[LR160]: The Petition must be signed
and veri ied by the petitioner, hether the AP or

relator. Although
the Rule does
not expressly
require a Certi
ication against orum Shopping
and
D CANNOT be dismissed or lack o

a Petition or
such a certi ication because a MTD onany ground

is a prohibited pleading under the Rule. o ever,
Rule 7, sec. 5, hich is the general rule on all
initiatory pleadings,
may already be incorporated in
the standard ormat.
75

[B] PARTIES
[C] BODY
Comment [LR161]: Note that under sec. 10, a

general denial is not allo ed/
1. Supporting Affidavits of respondents and their witness/es

2. Statement as to:
2.1. lawful defenses to show that respondent/s did not violate or threaten with violation
the rights subject of the Petition;
2.2. the steps or actions taken to determine the fate or whereabouts of the AP and the
persons responsible for the threat, act or omission
2.3. all relevant information in the possession of the respondent pertaining to the threat,
act or omission against the AP;
2.4. [if the respondent is a public official/employee], add :
actions taken or to be taken:
a. to verify the identity of the AP;
b. to recover and preserve evidence related to the death or disappearance of
the person identified in the petition which may aid in the prosecution of the person/s responsible;
c. to identify witnesses and obtain statements from them concerning the death
or disappearance;
d. to determine the cause or manner, location and time of death, or
disappearance as well as any pattern or practice that may have brought about the death or
disappearance;
e. to identify and apprehend the person/s responsible;
f. to bring the suspected offenders before a competent court.
3. Opposition to Interim Reliefs applied for
[D] Reliefs
[E] Date and Place
[G] VCFS
76
[C] BODY
1. Supporting Affidavits of respondents and their witness/es
2. Statement as to:
2.1. Lawful defenses to show that respondent/s did not violate or threaten with violation
the rights subject of the Petition;
2.2. Disclosure of the data or information about the petitioner, the nature of such data
or information and the purpose for its collection;
2.3. The Steps or actions taken by the respondent/s to ensure the security and
confidentiality of the data or information; and
2.4. The currency and accuracy of the data or information held;
2.5. Other allegations relevant to the resolution of the proceeding;
3. Opposition to Interim Reliefs applied for
[D] Reliefs
[E] Date and Place
[G] VCFS
77
Comment [LR162]: Note that

a general denial is
not allo ed; see ho ever la ul de enses that may

be invoked.
Comment [LR163]: National security,

state
secrets, privileged
communication,
con identiality o
the source o in ormation o media and others may

be invoked. See also Neri case on Executive
Privilege.
Pa e : [ ] Comment [LR
Lizz Razon
/ /
PM
The Petition must allege the ff:

1. Personal circumstances of petitioner and respondent/s
2.The right subject of the Petition and the act/s allegedly violative of said right/s
3. Any investigation conducted specifying names, personal circumstances and addresses of the investigating
authority or individuals as well as the manner and conduct of the investigation, together with any report
4. Actions and recourses taken by petitioner to determine the fate and whereabouts of the AP and the identity of
persons responsible for the threat or violation (sec. 5, Amparo)
Pa e : [ ] Comment [LR
Lizz Razon
/ /
PM
Court may order any person in possession or control of a designated land or other property to permit entry for the
purpose of inspection, measurement, or photographing of the property or any relevant object or operation thereon.
The application of IO must state in detail the place/s to be inspected and must be supported by affidavits or
testimonies of witnesses having personal knowledge of the enforced disappearance or whereabouts of the AP. The
IO shall specify the person/s authorized to inspect and the date, time and manner of inspection and other conditions
to protect the constitutional rights of all parties. The IO is good only for 5 days, unless extended by the court for
justifiable reasons. (Sec. 14b, Amparo) Note that the IO may also be availed of by the respondent (Sec, 15,
Amparo)
* Compare requirements for IO with Search
Warrant requirements under R126. Note that an IO is not a SW and does not require PC.

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ON WRITING, LEGALLY

PLEADINGS AND OTHER LEGAL DOCUMENTS IN CIVIL PROCEDURE

b. Action to Quiet (or Remove Cloud on) Title

PLEADINGS AND OTHER LEGAL FORMS IN CRIMINAL PROCEDURE

APPEALS AND OTHER RESORTS TO APPELLATE COURTS IN CRIMINAL AND

VIII. FORMS RELEVANT TO THE WRITS OF AMPARO AND HABEAS DATA

3. the docket number, if assigned (Sec. 1,

Comment [G2]: The TITLE indicates the

EREFORE it is rsctflly ry, ft r tic ri, t t t ft rr t

Fifty housand Pesos

SUBSCRIBED AND SWORN O before me in the City of _______________ on this day of

Comment [G3]: The JURAT accompanies

Comment [4]: The use of Community

Republic of the Philippines

(Sec. 4, par. 2, Rule 7, ROC).

Under Sec. 4, par.3, Rule 7, a verification

Comment [G7]: 1994 and 2004 Bar

: Pleadings required to be verified

. Certifition ginst orum Shopping

. Combined Verifi tion nd Certifition ginst orum Shopping

(Sgd.) C.. HILFIGER

Comment [G8]: Under Rule 7, Sec. 5, the

Comment [G9]: 2004 Bar Exams

H. equest for nd oti e of hearing

Quezon City, Branch

Proof of personal servi e

Copy furnished through personal service:

sCounsel for the Defendant

Comment [tG10]: NOTE: The Notice of

Atty. Mitch McDeere

Counsel for the Defendant

Comment [G11]: The requirement is for a

registered mail in accordance with Section , Rule of the Rules of Court:

TO THE TRUTH OF THE FOREGOING, I have signed this Affidavit on April

(Sgd.) HARPER LEE

City of Manila, April

Comment [G16]: The Notary Publics seal

[1] Regional Trial Court

Quezon City, Branch

4. Statement of Cause(s) of Action

Comment [G18]: 1976, 1982, 1985,

Comment [G19]: This particular

Comment [G20]: A new requirement

REGIONAL TRIAL COURT

4. Statement of Cause(s) of Action

Comment [G24]: Please note that this

REGIONAL TRIAL COURT

4. Statement of Cause(s) of Action

REGIONAL TRIAL COURT

National Capital Judicial Region

- versus YOKO NGA,

Comment [G29]: 1976 and 1983 Bar

e execution ell the

Comment [G30]: Rule 7, section 5

REGIONAL TRIAL COURT

4. Proposed stipulation of facts and issues

- versus LAKISA HIRAP,

Extinguishment of the alleged claim made by the entity Regency

Comment [G34]: NOTE: There is no need

[6] 5.1. Defendant intends to present the following witnesses:

National Capital Judicial Region

Comment [G37]: 1988 and 2002 Bar

LAKI ASSET COMPANY,

- versus DAMI UTANG CORPORATION,