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REPUBLIC OF THE PHILIPPINES

COURT OF APPEALS
MANILA
Thirteenth Division
Janice Sombilon Reed, for
herself and in behalf of her
minor
child,
Seith
Cody
Sombilon Reed, and her legal
spouse, Cameron Keith Reed,
Petitioners-Appellees,
-versus-

CA G.R. No. CV-105604


(Sp. Proc. No. 14-131491)

Office of the Civil Registrar


for the City of Manila, Office
of
the
Civil
Registrar
General & Administrator of
the
National
Statistics
Office, and John Doe, the
Unknown Biological Father of
Seith Cody Sombilon Reed,
Respondents.
Republic of the Philippines,
Oppositor-Appellant.
x-------------------------------------x

MOTION TO ADMIT APPELLEES BRIEF


WITH
ENTRY OF APEARANCE
(EX ABUNDANTI AD CAUTELAM)
PETITIONERS-APPELLEES, by counsel, unto this Honorable
Court, respectfully state and depose THAT:
1.

Sometime in November 2015, undersigned counsel received


a copy of this Honorable Courts Resolution dated October
26, 2015, requiring the Petitioners-Appellees to file the
Appellees Brief within forty Five (45) days from receipt of the
Oppositor-Appellants Brief.

2.

On January 28, 2016, undersigned counsel received a copy


of the Oppositor-Appellants Brief thereby giving the
petitioners-appellees up to March 13, 2016 within which to
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comply with the Resolution of this Honorable Court dated


October 26, 2015.
3.

However, March 13, 2016 falls on a Sunday, thus, giving


Petitioners-Appellees until March 14, 2016 within which to
file its Appellees Brief.

4.

Unfortunately, due to the undersigned counsels heavy


professional workload such as daily court appearances and
preparation of pleadings on other equally important cases,
the latter requests this Honorable Court to grant an
extension of additional 30 days within which to comply with
the Honorable Courts Resolution dated October 26, 2015.
The Honorable Court granted such motion on its April 5,
2016 Resolution.

5.

On April 12, 2016, the undersigned counsel filed a motion to


withdraw as counsel of the appellee due to professional and
personal reasons, which is irreconcilable in nature between
the undersigned and the appellees, and that an additional
30-day period be given to the appellees to comply with the
filing of the appellees brief. Said motion was noted by the
Honorable Court.

6.

However, a month after filing the said motion to withdraw,


the appellees went to the undersigned counsel pleading that
the latter remain as her counsel because she cannot find
another lawyer which can represent her and since the
undersigned counsel is already familiar with the said case,
the appellee pleaded that the undersigned counsel return as
her lawyer in this case for the higher interest of justice.

7.

The undersigned counsel believes that it is his moral duty to


accept again the case of the appellee since it might
prejudice her right if no one will appear or represent her as
her counsel. A provided in Canon 2, Rule 2.1 of the Code of
Professional Responsibility,
A lawyer shall not reject, except for valid
reasons, the cause of the defenseless or
oppressed.

8.

Also, the appellee heavily depends on her husband on


decision makings. The husband of the appellee is an active
U.S. military personnel and his decision to get again the
services of the undersigned counsel was conveyed to the
appellee belatedly. It is only after the husband of the
appellee gave his decision that the appellee went to the
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undersigned counsel to plead that the latter represent her


again in this case.
10. Delaying the submission of the appellees brief was
never the intention of the appellee nor of the
undersigned counsel. It is in the records of the Honorable
Court that the undersigned counsel has already withdrawn
from the case, however, due to the abovementioned
incidents which were beyond the control of the appellee nor
of the undersigned counsel, this appellees brief was only
filed on this date.
11. Hence, this motion.

ENTRY OF APPEARANCE
AS COUNSEL
12. Please re-enter the appearance of the undersigned as
counsel for the appellees, JANICE S. REED and in behalf of
her minor child SEITH CODY SOMBILON REED, with their
express conformity as indicated below, in this case.
Henceforth, kindly address all pertinent notices to the
undersigned at the address given below.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed
of this Honorable Court that the Appellees Brief be ADMITTED
by the Honorable Court and to note the entry of appearance of
the undersigned counsel.
Other just, equitable and proper remedies and relief under
the premises are likewise prayed for.

Makati City for Manila, Philippines, June 13, 2016.

ATTY. APOLLO X.C.S. SANGALANG


Counsel for the Respondent-Appellant
IBP Lifetime No. 06541; IBP-PPLM Chapter
PTR No. MKT 5336403-1/26/2016
MCLE Compliance No. MCLE no. V-002-1060,
APRIL 20, 2016, PASIG CITY
Roll of Attorney No. 40222
5th Floor Builders Center
170 Salcedo Street, Legaspi Village
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Makati City 1229


Tel. 208-2606; Cel. 0917-821-6848
Email: apollo.sangalang@lawyer.com

With my Conformity:

JANICE SOMBILON REED


Petitioner-appellee
EXPLANATION AND COPY FURNISH
(Pursuant to Section 11, Rule 13 of the 1997 Rules of
Civil Procedure)
The foregoing Motion to Admit Appellees Brief with Entry of
Appearance Ex Abundanti Ad Cautelam and the Appellees
Brief will be filled personally to this Honorable Court and served
to the Office of the Solicitor General, as counsel of the Republic of
the Philippines, by registered mail due to lack of office personnel
to effect personal service.

APOLLO X.C.S. SANGALANG


HON. JOHVIE M. VALENTON
Associate Solicitor
134 Amorsolo Street, Legaspi Village
Makati City
OFFICE OF THE SOLICITOR GENERAL
Counsel for the Oppositor-Appellant
134 Amorsolo Street, Legaspi Village
Makati City

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