Professional Documents
Culture Documents
COURTOF APPEALS
Cebu City
NINETEENTH DIVISION
-versus-
x--------------------------------------------------------------------/
MEMORANDUM OF AUTHORITIES
(FOR THE ACCUSED-APPELLANTS)
ISSUE
ARGUMENTS/DISCUSSIONS
1
2
But since
In fact,
procedure. Even law students know this rule. Hence, the failure of
Atty. Gako to observe this very basic rule is a clear example of gross
or palpable negligence committed by a lawyer. Thus, the Honorable
Appellate Court must step in and accord what is available relief to
the accused-appellants.
3
4
In the case of Apex Mining Inc. vs. CA6, the Supreme Court
said, thus
Accused-
appellants expected him that he will do what was good for them at
that time.
xxxxx
opportunity
for
the
proper
and
just
by
the
Constitution.
Thus,
the
xxxxx
xxxxx
10
xxxxx
xxxxx
11
xxxxx
12
xxxxx
xxxx
xxxx
13
xxxxx
Clearly, accused-appellants
PRAYER
14
15
Copy Furnished:
The Honorable City Prosecutor (personally served)
Lapulapu City Prosecutors Office
Lapulapu City
Received By _________________ on _____________
The Clerk of Court (personally served)
RTC Branch 27
Lapulapu City
Received By __________________ on ______________
The Solicitor General
Office of the Solicitor General
#134 Amorsolo Street
Legaspi Village, Makati City
1229
Registry Receipt No. _____________, dated ____________
Atty. Gongie
Counsel for Private Respondent
RCBC Building
Makati City.,
Makati
Registry Receipt No. ____________, dated _____________
EXPLANATION
Copy of this Memorandum is personally served to the
Lapulapu City Prosecutors Office and RTC-27, Lapulapu City.
16
AFFIDAVIT OF SERVICE/MAILING
I, Juan Tamad of legal age, Filipino, single, and a resident of Mandaue
City, Cebu, Philippines, after being sworn in accordance with law, do hereby
depose and state: THAT
1. I am at present the clerk/messenger of the ANGTUDS LAW OFFICE
located at Keppel Building, Ayala Business Park, Cebu City. On June
15, 2010, I served through personal service and/or registered mail
copies of this Memorandum to:
The Honorable City Prosecutor (personally served)
Lapulapu City Prosecutors Office, Lapulapu City
The Clerk of Court (personally served)
RTC Branch 27
Mandaue City, Lapulapu City
The Solicitor General
Office of the Solicitor General
#134 Amorsolo Street
Legaspi Village, Makati City, 1229
Atty. Gongie
Counsel for Private Respondent
RCBC Building, Makati City
Makati City
17
Juan Tamad
Affiant
SSS ID No. 0623473095
18