SUI GENERIS EXCLUSIVE NOTES (SGEN

)

LEGAL FORMS AND WRITING

JANEIT MORALLOS PAJILA

LEGAL FORMS AND WRITING JANEIT PAJILA

1

TABLE OF CONTENTS
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 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 b. Action to Quiet (or Remove Cloud on) Title c. Action for Declaratory Relief d. Quo Warranto PLEADINGS AND OTHER LEGAL FORMS IN CRIMINAL PROCEDURE A. Complaint-Affidavit and Counter-Affidavit LEGAL FORMS AND WRITING JANEIT PAJILA 2

II.

III.

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
IV.

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 D. Holographic Will E. Notarial Will F. Attestation Clause for a Notarial Will G. Acknowledgement of a Notarial Will H. Donation Inter Vivos I. Acknowledgment of Nominee Status with Assignment of Shares J. Secretary’s Certificate K. Board Resolutions 1. Authority to Act 2. Increase in number of directors and necessary amendment to the Articles of Incorporation LEGAL FORMS AND WRITING JANEIT PAJILA 3

V.

VI.

in civil cases a. O. P. M. from RTC (on pure questions of law) or CA (in appellate jurisdiction) to SC LEGAL FORMS AND WRITING JANEIT PAJILA 4 . from RTC (as trial court) to SC B. from RTC (as trial court) to CA c. APPEALS AND OTHER RESORTS TO APPELLATE COURTS IN CRIMINAL AND CIVIL PROCEDURE A. from MTC (as trial court) to RTC (in appellate jurisdiction) b. from RTC (as appellate court) or from quasi-judicial agencies to CA 2. N. R.L. Q. Ordinary Appeals 1. 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) S. from MTC (in original jurisdiction) to RTC (in appellate jurisdiction) b. Chattel Mortgage VII. from RTC (in original jurisdiction) to CA 2. Petitions for Review 1. in criminal cases a.

Page No. Book No.000. Manila ____________________.000) for exemplary damages. -versusCivilCase No. Plaintiff.COMMON FORMS A.1.) JUAN CRUZ Notary Public Until __________________ PTR No.50. _______________ issued on __________________ at _____________________. _______________ Issued at ______________ On ___________________ Doc. x------------------x B. Other just and equitable reliefs are also prayed for. LEGAL FORMS AND WRITING JANEIT PAJILA 5 . Defendant.50. that the defendant be ordered to pay the plaintiff the amount of One Million Pesos (Php. Series of 2007. (Sgd.000) for actual and compensatory damages. Fifty Thousand Pesos (Php. C. Fifty Thousand Pesos (Php._______________ For _______________________ ______________________.000) for attorney’s fees. after notice and hearing. No. and Fifty Thousand Pesos (Php.50. affiant exhibiting before me his community tax certificate no. Jurat SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day of _________________. Caption and Title Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 1. Prayer PRAYER WHEREFORE it is respectfully prayed.000) for moral damages.

Certification against Forum Shopping CERTIFICATION AGAINST FORUM SHOPPING Republic of the Philippines ) City of _______________ ) s.s. To the best of his knowledge.D. Replevin 3. He has read it and the allegations therein are true and correct of his own knowledge or based on authentic records. (Sgd. Complaints with application for injunction or attachment 4. Complaints for a. Answer to complaint or counterclaim based on actionable documents 5. Change of Name E. after having been duly sworn in accordance with law deposes and states that: 1. Hilfiger. Unlawful detainer c. 2. 3. Verification VERIFICATION Republic of the Philippines ) City of _______________ ) s.) JUAN DELA CRUZ PLUS: Jurat LEGAL FORMS AND WRITING JANEIT PAJILA 6 . deposes and states that: 1. (Sgd. Petitions for a. there is no such pending action or claim.) JUAN DELA CRUZ PLUS: Jurat NOTE: Pleadings required to be verified 1.K. 4. Forcible entry b. after having been duly sworn in accordance with law. C.K. Habeas Corpus e.s. Certiorari b. C. He has caused its preparation 3. If he should learn that a similar action or claim has been filed or is pending he shall report such fact within five (5) days from the discovery to this Honorable Court. He is the plaintiff in the case entitled (title of the case). Mandamus d. tribunal or quasi-judicial agency. He is the plaintiff in the pleading/document entitled (pleading/document being verified) 2. Prohibition c. He certifies that he has not commenced any action or filed any claim involving the same issues before any other court. Hilfiger. All pleadings under the Rules of Summary Procedure 2.

should I learn of such a case. Combined Verification. should I learn of such a case. I have signed this instrument on _____________. (Sgd. C. JUAN DELA CRUZ. Quezon City LEGAL FORMS AND WRITING JANEIT PAJILA 7 . 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. Branch 39 Please submit the foregoing Motion to the Court for its consideration and approval immediately upon receipt hereof and kindly include the same in the court’s calendar for hearing on Friday. ATTICUS FINCH 1 MockingBird Street Timog Avenue.F. 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. (Sgd. do hereby state that: I am the Chief Executive Office of Alis Di-yan Company and in such capacity. 13 April 2007 at 8:30 in the morning. IN WITNESS WHEREOF. of legal age.) JUAN DELA CRUZ PLUS: Jurat G. I shall notify the court within five (5) days from my notice. and Statement of Material Dates VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING I. I have read its contents and affirm that they are true and correct to the best of my own personal knowledge.) JUAN DELA CRUZ PLUS: Jurat Forum H. I have signed this instrument on _____________. Request for and Notice of hearing REQUEST FOR & NOTICE OF HEARING THE BRANCH CLERK OF COURT Metropolitan Trial Court Quezon City. I have received a copy of the [Order/Resolution/Decision] of the Court on 13 April 2007. I have read its contents and affirm that they are true and correct to the best of my own personal knowledge. caused this Complaint to be prepared. caused this Complaint to be prepared. Certification against Shopping. IN WITNESS WHEREOF. do hereby state that: I am the Chief Executive Office of Alis Di-yan Company and in such capacity. Combined Shopping Verification and Certification against Forum VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING I. I shall notify the court within five (5) days from my notice. of legal age.K. Hilfiger.

) and its attachment were served on Atty. a messenger of Atty. etc. (Sgd.Please take notice that counsel has requested to be heard on Friday. deposes and states: That on ______________________. 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. Mitch McDeere Counsel for the Defendant 2 The Firm Laguna Street. Quezon City Registry Receipt No. (Sgd. JUAN DELA CRUZ. after being duly sworn. AFFIDAVIT I. Jang Geun Suk with office address at __________________.) JUN CRUZ Counsel for Defendant 2 The Firm Laguna Street.s. Quezon City J. Proof of personal service Copy furnished through personal service: Atty. Mitch McDeere Counsel for the Defendant 2 The Firm Laguna Street. Quezon City I. ________ Post Office ________________ Date _____________________ EXPLANATION The foregoing (designation of pleading. I served a copy of the following pleadings/papers by registered mail in accordance with Section 10. Rule 13 of the Rules of Court: Nature of Pleading/Paper ________________________ ________________________ LEGAL FORMS AND WRITING JANEIT PAJILA 8 . 13 April 2007 at 8:30 in the morning.) JANG GEUN SUK Republic of the Philippines ) City of _______________ ) s. Proof of service by registered mail (with Explanation for failure to serve personally) Copy furnished through registered mail: Atty. motion.

Roll number. address. I have signed this Affidavit on 13 April 2007. as evidenced by Registry Receipt No. TO THE TRUTH OF THE FOREGOING. Mitch McDeere Counsel for the Defendant 2 The Firm. Atty. _________________ entitled ____________________ by depositing a copy in the post office in a sealed envelope. signature.) JUAN DELA CRUZ Affiant PLUS: Jurat K. PTR number City of Manila.. IBP OR No. (Sgd. Place. 13 April 2007. Philippines. Metro Manila Roll No. Laguna Street. _____________________ attached and with instructions to the post master to return the mail to sender after ten (10) days if undelivered..in Case No. date. date and place of issue LEGAL FORMS AND WRITING JANEIT PAJILA 9 . IBP receipt number. Quezon City. in the City of Manila. date and place of issue PTR OR No. plainly addressed to (name of party or his/her attorney) at _______________ with postage fully paid.

include the following after the 1st paragraph: This instrument. Book No. M. No. NOTE: If the instrument conveys 2 or more parcels of land. has been signed on the left margin of each and every page thereof by ___________ and his witnesses (if any).s. personally appeared ATTICUS FINCH. (Sgd. IN WITNESS WHEREOF. including the page on which this acknowledgment is written. and who acknowledged to me that the same is his free act and deed. having been signed by ______________ and his witnesses (if any). with [Valid Identification Document] (Driver’s License No. TARIO Notary Public Until __________________ PTR No. include the following after the 1st paragraph: This instrument relates to the sale (or mortgage) of ___ parcels of land. Series of 2007 NOTE: If the instrument consists of 2 or more pages. and consists of ___ pages including the page on which this acknowledgment is written. _______________ Issued at ______________ On ___________________ Doc. on the left margin. BEFORE ME. Notice of Appeal NOTICE OF APPEAL LEGAL FORMS AND WRITING JANEIT PAJILA 10 . consisting of ___ pages. O. Page No. each and every page of which. and sealed with my Notarial seal. Philippines. N25-07-007777) issued by the [official agency] (Land Transportation Office) on 10 January 2007. year and place written.L. this 13th day of April. I have set my hand and affixed my Notarial seal on the day. and sealed with my Notarial seal. Acknowledgment Republic of the Philippines City of Manila ) ) s. known to me to be the same person who executed the foregoing instrument. 2007 in the City of Manila.) N.

ABC. Quezon City. (Sgd.Defendant. Quezon City LEGAL FORMS AND WRITING JANEIT PAJILA 11 . respectfully appeals to this Honorable Court the Decision of the lower court dated 13 April 2007. by counsel. a copy of which he received on 26 April 2007.) MITCH MCDEERE Counsel for Defendant 2 The Firm Laguna Street. 2 May 2007.

where he may be served with summons and other pertinent processes. Quezon City which it leased to defendant under the terms and conditions stated in the Contract of Lease dated 1 January 2005. [5] WHEREFORE. which contract expires on 31 December 2006. Tuna Compound. respectfully states that: [2] 1. Despite demand duly made and received.000. Plaintiff. x ----------------------------------. A Certification to File Action is attached as ANNEX C. Complaint (and other initiatory pleadings) 1.000. Resort to the Barangay conciliation system proved useless as defendant refused to appear before the Lupong Tagapamayapa.00). Tuna Compound. Quezon City. Defendant’s continued occupation of the premises has also forced plaintiff to sue and to incur legal expenses amounting to Fifty Thousand Pesos (P50. plaintiff then asked defendant to vacate the premises. PLEADINGS AND OTHER LEGAL DOCUMENTS PROCEDURE A. A copy of the contract is attached as ANNEX A. Branch 33 IN CIVIL ALIS DI-YAN COMPANY. 5. of legal age.versus YOKO NGA. Defendant’s act of dispossession has caused plaintiff to suffer material injury because plaintiff’s 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. LEGAL FORMS AND WRITING JANEIT PAJILA 12 Civil Case No. [4] 4.x COMPLAINT PLAINTIFF. by counsel.00) for Attorney’s fees. [3] 2. plaintiff informed defendant of its intention not to renew the lease as it would use the property for its business expansion. Tuna Compound. Complaint for ejectment with damages [1] Regional Trial Court National Capital Judicial Region METROPOLITAN TRIAL COURT Quezon City. Defendant is a Filipino.II. Plaintiff owns that property located at 112 Ocean Drive. Defendant. 3.500 representing rentals on the machineries for seven (7) months and Fifty Thousand Pesos (P50. A copy of plaintiff’s letter to defendant is attached as ANNEX B. defendant has refused to vacate the premises and continues to occupy the property without plaintiff’s consent. Upon expiration of the contract. Quezon City. Plaintiff is a foreign corporation organized and existing under the laws of France with business address at 111 Ocean Drive. 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. . single and currently resident of 112 Ocean Drive. 2222 For: Ejectment .

[7] (Sgd. [8] Verification and Certification against Forum Shopping 2. 13 April 2007.) JUAN DELA CRUZ Counsel for Plaintiff [Address] PLUS: 1.Other just and equitable reliefs are also prayed for. [6] Quezon City. Jurat LEGAL FORMS AND WRITING JANEIT PAJILA 13 .

of legal age. [5] WHEREFORE. with legal interest. plaintiff respectfully prays for judgment in his favor through a Decision directing defendant to pay him NINE HUNDRED THOUSAND PESOS (P900. These amounts now total Nine Hundred Thousand Pesos (P900. Defendant’s obligation is due and demandable and plaintiff is entitled to the payment of the entire amount of Nine Hundred Thousand Pesos (P900. Defendant.00) as Attorney’s Fees.2. where he may be served with summons and other processes. Plaintiff. Defendant promised to pay these amounts on an installment basis monthly. respectfully states that: [2] 1. 4. Makati City ESTA PADORA. [3] 2. despite notice on him to appear.00). and resident of 6750 Forbes Park. defendant failed or has refused to pay any amount to plaintiff as no installment payment has even been made.000. of legal age and resident of 6752.00) plus legal interest.000. both oral and written. a copy of which is attached as ANNEX C. Plaintiff is a Filipino. 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.) JUAN DELA CRUZ Counsel for Plaintiff LEGAL FORMS AND WRITING JANEIT PAJILA 14 Civil Case No. Despite repeated demands. [6] Quezon City for Makati. a Certification to File Action. . [7] (Sgd.00). defendant is also a Filipino. 13 April 2007. Thus. Other just and equitable reliefs are also prayed for. defendant borrowed certain amounts from plaintiff. A copy each of plaintiff’s two (2) demand letters is attached as ANNEX A and B. Complaint for sum of money [1] Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 101. Resort to the Barangay Conciliation process proved fruitless as defendant failed to appear.00).x COMPLAINT PLAINTIFF.000. as ACTUAL DAMAGES and FIFTY THOUSAND PESOS (P50. Makati City.versus MANGGA GANTSO. [4] 3. by counsel. was issued by the Barangay Chairman. By reason of defendant’s unreasonable failure or refusal to pay his due and demandable obligation. 6. 000882 For: Sum of Money . 5.000. Makati City.000. Sometime in January 2005 and over a period of six (6) months. x -------------------------. Forbes Park.

[Address] PLUS: [8] Verification and Certification against Forum Shopping LEGAL FORMS AND WRITING JANEIT PAJILA 15 .

plaintiff demanded from defendant the return of the car but defendant failed and refused to do so. Manila.x COMPLAINT Plaintiff. 5. On 15 March 2005. judgment be rendered declaring plaintiff to be lawfully entitled to the possession of the car and sentencing defendant to pay its value.3.00). Plaintiff is ready. rented from plaintiff for a period of one (1) week. which defendant. Plaintiff is the general manager of Hurts Rent-A-Car with offices at Makati City. 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 accordance with the Rules of Court and. [5] WHEREFORE. 13 April 2007. Complaint for Replevin [1] Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 101. Makati City HURTS RENT-A-CAR. 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.000.) MITCH MCDEERE Counsel for the Plaintiff [Address] PLUS: [8] Verification and Certification against Forum Shopping LEGAL FORMS AND WRITING JANEIT PAJILA 16 . [4] 3. 000088 . x----------------------------------. defendant is a Tongan. Roxas Boulevard. Hurts Rent-A-Car is the registered owner of a Honda CRV with license plate number XLV-675. by counsel. Defendant. respectfully states that: [2] 1.versus YOKO NGA. 4. represented by AKIN NAYAN. [3] 2. temporarily residing at Bayview Hotel. Civil Case No. [6] Quezon City for Makati City. [7] (Sgd. Its present value is approximately Nine Hundred Thousand Pesos (P900. Plaintiff. willing and able to give bond in defendant’s 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. on 3 March 2005. after hearing.

00) to be paid within the first five (5) days of each month. Pasig City while defendant resides at 2 Frisco Street. 5. [3] 2. Pasig City for a monthly rental of One Thousand Pesos (P1. Pasig City. 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. Plaintiff has been paying the rentals as they fall due each month. without fail. Plaintiff and Defendant are both Filipino citizens and of legal age. defendant leased to plaintiff the premises at 1-A Cruz Street. on 4 April 2006. However.4. [7] (Sgd. plaintiff resides at 1-A. Defendant. 3.00). Civil Case No. [6] Quezon City for Pasig City. Complaint to set period of years for lease [1] Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 161.versus NAGPA PAUPA. x ---------------------. Pasig City NANG UUPA. by counsel.x COMPLAINT PLAINTIFF.) JUAN DELA CRUZ Counsel for Plaintiff [Address] PLUS: [8] Verification and Certification against Forum Shopping LEGAL FORMS AND WRITING JANEIT PAJILA 17 . On 1 January 2003.000. 13 April 2007. defendant gave notice to plaintiff that he is terminating the lease agreement by the end of August 2006. 00111 . respectfully states that: [2] 1. Considering that the period of lease has not been fixed.000. it is respectfully prayed that this Honorable Court fix a period of years for the lease between plaintiff and defendant. 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. [5] WHEREFORE. Plaintiff. There is no fixed period for the lease agreement except that rentals are to be paid by the month. where he may be served with summons. Cruz Street. [4] 4.

superceded by a Deed of Absolute Sale whereby plaintiff sold to defendant the parcel of land in question. 4. x ----------------------------------. repleads and incorporates by reference all the foregoing insofar as they are material and additionally submit that the Complaint should be dismissed because: 5.versus YOKO NGA. He specifically denies the contents of paragraphs 4 to 6 for the reasons stated in the Affirmative Defenses below. 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. Plaintiff has no capacity to sue as it is a foreign corporation doing business in the Philippines without a license. Quezon City ALIS DI-YAN COMPANY. respectfully states that: Admissions/Denials [2] personal plaintiff’s Defenses 1. Defendant reiterates.1. .2. The Complaint fails to state a cause of action as the Contract of Lease (ANNEX A) was.x ANSWER (With COUNTERCLAIM) DEFENDANT. before its expiration. Defendant. Plaintiff. by counsel. Answer with affirmative defense and counterclaim 1. a copy of which is attached as ANNEX 1.B. Counterclaim LEGAL FORMS AND WRITING JANEIT PAJILA 18 . 3. He admits the contents of paragraph 1 only insofar as his circumstances but specifically denies the contents insofar as personal circumstances for the reason stated in the Affirmative below. Civil Case No.. Affirmative Defenses [4] 5. 2222 For : Ejectment 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. 5. Answer with compulsory counterclaim [1] Regional Trial Court National Capital Judicial Region METROPOLITAN TRIAL COURT Branch 33.

Other just and equitable reliefs are prayed for. Defendant reiterates. Moral Damages amounting to One Million Pesos (PHP1. [7] Quezon City. should I learn of such a case. [6] WHEREFORE. Defendant respectfully prays that judgment be rendered in his favor by dismissing the Complaint and granting defendant’s counterclaim by awarding defendant: (a) One Million Pesos as Moral Damages. 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.) YOKO NGA PLUS: 1. 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.1. I have signed this instrument on 13 April 2007. 6. IN WITNESS WHEREOF. [8] (Sgd. Jurat (IF any document is denied) 2.) JUAN DELA CRUZ Counsel for Defendant [Address] [9 & 10] VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING I. I have read its contents and affirm that they are true and correct to the best of my own personal knowledge.000/00) because his name and reputation were besmirched by this malicious and baseless suit.2.[5] 6. [11] Proof of Service (personal service or service by registered mail) LEGAL FORMS AND WRITING JANEIT PAJILA 19 . and (b) Fifty Thousand as Attorney’s Fees. (Sgd. in response. 13 April 2007. I shall notify the court within five (5) days from my notice. do hereby state that: I am the defendant in the case filed by Alis Di-yan Company for ejectment. I have caused the preparation of this Answer with Counterclaim.000.000.00) because he was compelled to secure services of counsel to vindicate his legal rights. Attorney’s Fees amounting to One Hundred Thousand Pesos (P100. as follows: 6. of legal age. YOKO NGA. I specifically deny the genuineness and due execution as well as the binding effect of the actionable documents pleaded by plaintiiff.

1. Defendant respectfully prays that judgment be rendered in his favor by 1. B-1. and b. Answer with counterclaim and cross-claim See Form No. granting defendant’s counterclaim by awarding defendant a.000) as Moral Damages. supra. but add-[5] Crossclaim 7. from defendant. 3. Jurat (IF document is denied) 3. [9 & 10] Verification and Certification against Forum Shopping 2. [6] WHEREFORE.2.000. Defendant reiterates. [7] Quezon City. [8] (Sgd. __________________. [11] Proof of Service (personal service or service by registered mail) LEGAL FORMS AND WRITING JANEIT PAJILA 20 . acting as such. dismissing the Complaint.) JUAN DELA CRUZ Counsel for Defendant [Address] PLUS: 1.50. and 2. In the event that defendant is made liable to plaintiff on the Complaint. he further prays that co-defendant MANGGA GANTSO be made liable to indemnify defendant in the same amount under the Crossclaim. Fifty Thousand Pesos (Php. One Million Pesos (Php. received consideration.000) as Attorney’s Fees. repleads and incorporates by reference all the foregoing insofar as they are material and additionally submit that he is entitled to indemnity and/or contribution from co-defendant MANGGA GANTSO in the event that he is made liable to plaintiff because co-defendant MANGGA GANTSO acted as the duly authorized agent of plaintiff in the sale of the property and. in the form of the purchase price.

000.2. Defendant resists plaintiff’s claims based on a failure to state a cause of action because of : 2. LEGAL FORMS AND WRITING JANEIT PAJILA 21 . Plaintiff’s lack of personality to sue and.000. respectfully submits her Pre-Trial Brief. BRIEF STATEMENT OF CLAIMS AND DEFENSES 2. second. Defendant also interposed a compulsory counterclaim for Two Million Pesos (PHP2. a schedule of payments. WILLINGNESS TO ENTER INTO AN AMICABLE SETTLEMENT AND POSSIBLE TERMS OF ANY SUCH SETTLEMENT 1.000. defendant is open to the possibility of amicably settling this dispute. Plaintiff seeks principally to recover the amount of Twenty Two Million Eight Hundred Eighteen Thousand Nine Hundred Forty Eight Pesos and Thirty Centavos (PHP22. 2.3. 2. therefore.1. Plaintiff. Extinguishment of the alleged claim made by the entity Regency Furniture. 97-31312 .2.000.versus LAKISA HIRAP.00) as attorney’s fees. defendant respectfully submits that the desired terms of any amicable settlement would involve.00) for exemplary damages and One Hundred Thousand Pesos (PHP100. as follows: I. section 2 of the 1997 Rules of Civil Procedure.1. first.2.948. Defendant.000. [1 & 2] 1. x ------------------------------------. by counsel. a clarification of the actual extent of any obligation due and owing to plaintiff inasmuch as there is nothing to indicate defendant’s obligations to plaintiff and.00) for moral damages and Two Million Pesos (PHP2.30) with interest at twelve percent (12%) arising allegedly from unpaid orders delivered to defendant variously in 1989.C. 2. Civil Case No. Quezon City LAKISA LAYAW.2.2. not being the real party in interest under Rule 3.818. II. Subject to a concrete proposal that is fair and reasonable and a reciprocal manifestation of openness from plaintiff.1.x PRE-TRIAL BRIEF DEFENDANT. Pre-trial Brief Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 90. Pursuant to Rule 18 of the 1997 Rules of Civil Procedure.

2. ISSUES TO BE TRIED [4] 4.1.1.2. who will testify on the true circumstances leading to the filing of this suit against her. IV. 4.1. RESORT TO DISCOVERY [7] 6.2.2.e. Plaintiff’s personality to seek legal relief. Quezon City. 1997 and her reply to the demand letter. 13 April 2007.2.1. defendant reserves the right to resort to discovery before trial. EVIDENCE [6] 5. receipt of the demand letter dated January 5.1. [5] 5.1. to a concrete and reasonable request for discovery from plaintiff. Defendant submits that the following issues she put forward are subject to proof: 4. FACTS AND OTHER MATTERS ADMITTED BY THE PARTIES [3] 3. Defendant reserves the right to present any and all documentary evidence which shall become relevant to rebut plaintiff’s claims in the course of trial as well as any other witnesses whose testimony will become relevant to belie plaintiff’s witnesses.1. Plaintiff’s entitlement to the amount claimed.2.1. Subject to a concrete proposal for stipulation of additional facts from plaintiff during pre-trial or even thereafter.1. if necessary. defendant admits no other facts stated in the Complaint.1.2. Defendant herself.) JUAN DELA CRUZ Counsel for Defendant [Address] LEGAL FORMS AND WRITING JANEIT PAJILA 22 . her personal circumstances. 4. Plaintiff’s bad faith in filing this suit.2. V. i. Defendant’s entitlement to the claims made in her Compulsory Counterclaim as a result of plaintiff’s bad faith.. VI. 6. 5. Subject. Defendant submits that the following issues put forward by plaintiff are subject to proof: 4. An employee of Topless Enterprises with personal knowledge as to the true circumstances behind the alleged obligations due and owing in favor of plaintiff. defendant does not intend to avail of discovery at this time.2. Defendant intends to present the following witnesses: 5. (Sgd. Defendant admits only those facts stated in her Answer.III. 4. 3. Considering the relatively simple issues presented.1. RESPECTFULLY SUBMITTED. however.

MA BOLA Counsel for Plaintiff LEGAL FORMS AND WRITING JANEIT PAJILA 23 .Copy furnished: Atty.

. 27 April 2007 at 8:30 in the morning. The contract is for one (1) year and defendant is given that same period to reach the quota specified therein. LEGAL FORMS AND WRITING JANEIT PAJILA 24 Civil Case No. 2. Other just and equitable reliefs are also prayed for. 3333 For: Sum of Money .00).000. Allegedly. 13 April 2007. plaintiff’s Complaint states no cause of action and must be dismissed. For this reason. Quezon City. [3] WHEREFORE.D. plaintiff has failed to reach the quotas agreed upon under the Marketing Agreement dated 1 January 2006. as shown by the following: [2] 1.) JUAN DELA CRUZ Counsel for Defendant [Address] [4] REQUEST FOR & NOTICE OF HEARING THE BRANCH CLERK OF COURT Metropolitan Trial Court Branch 39. defendant now seeks to collect the sum of TWO HUNDRED THOUSAND PESOS (P200. (Sgd. Consequently. Defendant. by counsel. x --------------------------------------. Plaintiff.versus DAMI UTANG CORPORATION. Quezon City LAKI ASSET COMPANY. 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. defendant respectfully prays that the Complaint be DISMISSED for failure to state a cause of action.x MOTION TO DISMISS DEFENDANT. Motions 1. Quezon City Please submit the foregoing Motion to the Court for its consideration and approval immediately upon receipt hereof and kindly include the same in the court’s calendar for hearing on Friday. representing the balance of the proceeds due plaintiff under the said Marketing Agreement. the period of one (1) year has not expired. Motion to dismiss (with request for and notice of hearing) Republic of the Philippines National Capital Judicial Region METROPOLITAN TRIAL COURT Branch 39. plaintiff’s claim is premature as there is yet no breach of the Marketing Agreement until the period expires and the quota is not attained.

ATTICUS FINCH 1 MockingBird Street Timog Avenue. Quezon City Please take notice that counsel has requested to be heard on Friday. (Sgd. 27 April 2007 at 8:30 in the morning. Quezon City PLUS: [5] Proof of Service LEGAL FORMS AND WRITING JANEIT PAJILA 25 .) JUAN DELA CRUZ Counsel for Defendant 2 The Firm Laguna Street.

Motion for leave of court to file pleading explanation for service by registered mail) Republic of the Philippines SUPREME COURT Manila LAKI UTANG.) JUAN DELA CRUZ Counsel for the Petitioner [Address] PLUS: 1. is attached to this motion. Quezon City for Manila. Under existing rules.x MOTION FOR LEAVE OF COURT TO FILE REPLY WITH MOTION TO ADMIT ATTACHED REPLY PETITIONER. The Comment contains several allegations of fact and misinterpretations of the record that may mislead the court and need to be corrected. petitioner intends to file a Reply. [4] Request for and Notice of Hearing 2. [2] 2. Petitioner. Respondent.2. respectfully states that: (with [1] 1.R.versus DAMI LUPA. petitioner respectfully prays that he be granted leave of court to file a Reply and for the Court to admit the attached Reply. x ------------------------. petitioner seeks leave of this Court to file the said Reply. [3] WHEREFORE. pursuant to the 1997 Rules on Civil Procedure. a copy of which. No. a Reply can no longer be filed as a matter of course. Petitioner received a copy of respondent’s Comment to his petition on 3 January 2006. G. For this reason. (Sgd. ________ . by counsel. 5 January 2007. [5] Explanation for service by registered mail LEGAL FORMS AND WRITING JANEIT PAJILA 26 . Consequently.

The Answer admits the material allegations of the Complaint and has not tendered any issue. Plaintiff. On 6 July 2005. (Sgd.versus LAKISA HIRAP. Defendant. consequently. Motion for judgment on the pleadings Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39. plaintiff sued defendant for a sum of money in the amount of Nine Hundred Thousand Pesos (P900. a judgment on the pleadings may be rendered. Quezon City LAKISA LAYAW. 13 April 2007. 97-31312 For: Sum of Money LEGAL FORMS AND WRITING JANEIT PAJILA 27 .000. plaintiff respectfully prays a judgment on the pleadings be rendered in his favor. [4] Request for and Notice of Hearing 2.) JUAN DELA CRUZ Counsel for the Plaintiff [Address] PLUS: 1. x ------------------------. [5] Proof of Service Civil Case No. [1 & 2] 2. respectfully states that: 1.00).3. by counsel. [3] WHEREFORE. 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. Quezon City. In his Answer. .x MOTION FOR JUDGMENT ON THE PLEADINGS Plaintiiff.

x EX PARTE MOTION TO SET CASE FOR PRE-TRIAL PLAINTIFF. ripe for pre-trial. x ------------------------. Quezon City Please take notice that counsel has requested for the approval of the foregoing motion immediately upon receipt. defendant submitted her Answer to the Complaint. Complying with Rule 18. Quezon City. Ex parte motion to set for pre-trial Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39. Civil Case No. (Sgd. 97-31312 . by counsel. Copy furnished: MA. Section 1 of the 1997 Rules on Civil Procedure. [2] 2.) JUAN DELA CRUZ Counsel for the Plaintiff PLUS: [5] Proof of Service LEGAL FORMS AND WRITING JANEIT PAJILA 28 . 13 April 2007. plaintiff respectfully asks that this case be set for pre-trial. respectfully states that: [1] 1.versus LAKISA HIRAP. Quezon City LAKISA LAYAW. thereby causing the issues to be joined. On 1 June 2006. This case is. plaintiff respectfully prays that this case be set for pre-trial on a date convenient to this Honorable Court. [3] WHEREFORE. Plaintiff. thus. (Sgd.) JUAN DELA CRUZ Counsel for the Plaintiff [Address] [4] REQUEST AND NOTICE THE BRANCH CLERK OF COURT Regional Trial Court Branch 39.4. Quezon City Please submit the foregoing to the Court for its approval immediately upon receipt hereof. SSKA DERY 2 The Firm Laguna Street. Defendant.

Motion for postponement Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39.x MOTION FOR POSTPONEMENT PLAINTIFF. 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. (Sgd. plaintiff respectfully submits that his attendance in the Makati case becomes indispensable. Defendant. where he is scheduled to terminate cross-examination of the prosecution’s expert witness who will be available only on said date and time. 13 April 2007. Quezon City DILA TORY. Plaintiff. x ------------------------. 008877 . Civil Case No. 009988. Without impugning the importance of these proceedings. plaintiff respectfully prays that the trial scheduled on 5 May 2007 be POSTPONED to another date convenient to this Honorable Court. [1] 2. by counsel.versus PASEN SYOSO. otherwise. [3] WHEREFORE. [4] Request for and Notice of Hearing 2. Criminal Case No. respectfully states that: 1. This motion is prompted only by the foregoing reason and not for delay. Quezon City. the accused in said case would be deprived of the opportunity to confront and cross-examine a vital witness against her. On said date and time.5. 4. Bil Moko”. [2] 3. This case is set for trial on 5 May 2007 at 8:30 in the morning. [5] Proof of Service LEGAL FORMS AND WRITING JANEIT PAJILA 29 . Branch 139 for “People of the Philippines v.) JUAN DELA CRUZ Counsel for the Plaintiff [Address] PLUS: 1.

Plaintiff. within which to submit plaintiff’s Reply. Motion for extension of time Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39. by counsel. [3] WHEREFORE.) JUAN DELA CRUZ Counsel for Plaintiff [Address] PLUS: 1. 13 April 2007. respectfully states that: 1. x -----------------------------------. For this reason. the undersigned is constrained to ask for an additional fifteen (15) days from 10 May 2007. [5] Proof of Service LEGAL FORMS AND WRITING JANEIT PAJILA 30 . plaintiff respectfully prays that he be granted an additional fifteen (15) days from 10 May 2007. The undersigned counsel. Quezon City. within which to submit plaintiff’s Reply. or until 25 May 2007. 3. [4] Request for and Notice of Hearing 2. This motion is not intended for delay but is motivated only by the foregoing reason. Quezon City DILA TORY.x MOTION FOR EXTENSION OF TIME PLAINTIFF.6. 008877 . however.versus PASEN SYOSO. (Sgd. 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. He has been directed to file a Reply to defendant’s Answer by 10 May 2007. or until 25 May 2007. Defendant. [1 & 2] 2. Civil Case No.

summons were served on defendant on 20 March 2007.) JANG GEUN SUK Counsel for Plaintiff [Address] PLUS: 1. plaintiff is entitled to a declaration of default and the right to present evidence ex parte against defendant. a copy of which is attached as ANNEX A. (Sgd. Motion to declare defendant in default Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39. as indicated by the Sheriff’s Return of even date. 7 April 2007. [5] Proof of Service LEGAL FORMS AND WRITING JANEIT PAJILA 31 . no motion for extension of such period was filed nor was any granted motu proprio by this Honorable Court. Civil Case No. [4] Request for and Notice of Hearing 2. by counsel. defendant has failed to answer the Complaint against her. Quezon City ANAKIN SKYWALKER. Despite the lapse of time. Quezon City. 000909 .versus PADME AMIDALA. Defendant’s reglementary period to file Answer ended on 5 April 2007. 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. respectfully states that: 1. Plaintiff filed this Complaint against defendant on 1 March 2007. Defendant. x ---------------------------------.7. Plaintiff.x MOTION TO DECLARE DEFENDANT IN DEFAULT PLAINTIFF. [1 & 2] 2. [3] WHEREFORE.

x MOTION TO LIFT ORDER OF DEFAULT DEFENDANT.versus PADME AMIDALA. (b) the reglementary period has not lapsed because of the filing of the Motion to Dismiss within the period. this Honorable Court declared defendant in default on 7 April 2007 based solely on plaintiff’s Motion. and (c) the pendency of the Motion to Dismiss is prejudicial to the issue of defendant’s default. Plaintiff. [5] Proof of Service LEGAL FORMS AND WRITING JANEIT PAJILA 32 . filed two (2) days after the supposed lapse of the reglementary period. she filed a Motion to Dismiss on the ground that plaintiff’s 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. x ---------------------------------. which. 000909 . Motion to lift order of default Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39. Civil Case No. respectfully states that: 1. Five (5) days after service of summons and receipt of Complaint. as indicated on the “Request for and Notice of Hearing”. Consequently. 2. Under the circumstances.) JANG GEUN SUK Counsel for Defendant [Address] PLUS: 1. Quezon City ANAKIN SKYWALKER. [1 & 2] 3. 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. defendant respectfully prays that the Order of Default against her be LIFTED and that this Honorable Court resolve her Motion to Dismiss.8. 8 April 2007. [3] WHEREFORE. [4] Request for and Notice of Hearing 2. which was received by plaintiff’s counsel on 25 March 2007. the order of default should be lifted. was set for hearing on 10 April 2007. Quezon City. (Sgd. however. The Motion to Dismiss. by counsel. Defendant. Without waiting for the hearing on the Motion to Dismiss. was tolled by the filing of a Motion to Dismiss.

i. Rule 56. if filed. [4] WHEREFORE. Prohibition and Mandamus a. Certification against Forum Shopping. Quezon City.) 2. citizenship. Special Civil Actions 1. par. (State briefly the facts and circumstances under which the respondent/s exercising judicial functions acted without. section 2 applicable to petitions for certiorari. 51. jurisdiction or with grave abuse of discretion amounting to lack or excess of jurisdiction. Certiorari (with Injunction and/or TRO). Rule 46. 49. section 2 provides that Rules 46.) [3] 3. it is respectfully prayed that a writ of certiorari be issued ANNULLING the (act.E. (State the date on which copy of Decision was received and/or Resolution on Motion for Reconsideration. in the interim. and other documents. There is no appeal from such decision or any plain or adequate speedy remedy in the ordinary course of law. mandamus and prohibition.” LEGAL FORMS AND WRITING JANEIT PAJILA 33 . (State entitlement to Injunction and/or TRO.) JANG GEUN SUK Counsel for the Petitioner [Address] PLUS: [5] Combined Verification. or in excess of. A certified true copy (or duplicate original copy) of the Decision under review is attached as ANNEX A. respectfully states that: [2] 1. 6. [a] petitioner has a clear. Allege also that petitioner is ready to post a bond in an amount to be fixed by the Court conditioned upon the payment to respondents of any damages suffered arising from the writ should petitioner be found not to be entitled to the writ.e.) 4. [c] and that.) 5. will cause grave and irreparable injury to petitioner. Certiorari (Caption and Title) PETITION PETITIONER. except this petition. decision or finding) for being in grave abuse of discretion. 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. (Sgd. [b] which is threatened by an act or omission of respondents. legal right.. [1] 7 July 2007. section 6. 52 and 56 apply. denied. status and residence. that a preliminary injunction and/or temporary restraining order issue to ENJOIN any further proceedings by respondents. relevant or pertinent thereto. unless restrained. and Statement of Material Dates * Rule 65. 48. (State capacity of petitioner and respondent/s. by counsel. 2 expressly makes Rule 56.

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 Statement of Material Dates LEGAL FORMS AND WRITING JANEIT PAJILA 34 .e. There is no appeal from such decision or any plain or adequate speedy remedy in the ordinary course of law.. respectfully states that: [2] 1.) JANG GEUN SUK Counsel for the Petitioner [Address] PLUS: [5] Combined Verification. jurisdiction or with grave abuse of discretion amounting to lack or excess of jurisdiction. (Sgd. [1] 7 July 2007. [a] petitioner has a clear.) 4. (State briefly the facts and circumstances under which the respondent/s whether exercising judicial or ministerial functions acted without. Allege also that petitioner is ready to post a bond in an amount to be fixed by the Court conditioned upon the payment to respondents of any damages suffered arising from the writ should petitioner be found not to be entitled to the writ. [b] which is threatened by an act or omission of respondents. and that after due notice and hearing. or in excess of. Certification against Forum Shopping. legal right.) 5. will cause grave and irreparable injury to petitioner. (If applicable. except this petition.) 2. (State capacity of petitioner and respondent/s. 6.) [3] 3. status and residence. citizenship. A certified true copy (or duplicate original copy) of the Decision under review is attached as ANNEX A. Quezon City. by counsel.b. Prohibition (Caption and Title) PETITION PETITIONER. i. unless restrained. if filed. [c] and that. a writ of prohibition issue directing respondent/s to desist absolute and perpetually from further proceedings (in the said action or matter). [4] WHEREFORE. state the date on which copy of Decision was received and/or Resolution on Motion for Reconsideration. denied. (State entitlement to Injunction and/or TRO.

it is respectfully prayed that. Petitioner has no appeal from such decision or any plain or adequate speedy remedy in the ordinary course of law.) 3. addresses. Certification against Forum Shopping.) (State the capacity of petitioner and respondent/s and their [3] 2. by counsel. a writ of mandamus issue commanding respondent/s forthwith to: (state the act required to be done). [4] WHEREFORE. (Sgd. or unlawfully excluded the petitioner from the enjoyment of a right or office to which the petitioner is entitled. (State the facts and circumstances whereby respondent/s unlawfully neglected the performance of an act which the law specifically enjoins as a duty resulting from an office. and Statement of Material Dates LEGAL FORMS AND WRITING JANEIT PAJILA 35 . except this petition. [1] 7 July 2007. trust or station. with costs against them. respectfully states that: [2] 1. after due notice and hearing. Quezon City.) JANG GEUN SUK Counsel for the Petitioner [Address] PLUS: [5] Combined Verification.c. Mandamus (Caption and title) PETITION PETITIONER.

defendants made similar representations to plaintiff as to ownership of the watch. Complaint in Interpleader NALI LITO.versus UMA AGAW and INA AGAWAN. Quo warranto. respectively. as first lien upon the subject matter of this action. where they may be served with pertinent notices. 3.2. ____________ . Plaintiff. plaintiff found a Gold Rolex Oyster watch. Quieting of Title. plaintiff resides at ________________ while defendants reside at _______________ and _______________. 7 July 2007. who claims no interest in the watch. [3] WHEREFORE. SCA No. Defendants. cannot determine the conflicting claims of defendants and thus seeks to compel defendants to interplead and litigate their several claims between themselves. x --------------------------------------. by counsel. 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. [4] Quezon City. Plaintiff. On or about 5 June 1999.x COMPLAINT PLAINTIFF.) JANG GEUN SUK Counsel for Plaintiff [Address] PLUS: [6] Verification and Certification against Forum Shopping LEGAL FORMS AND WRITING JANEIT PAJILA 36 . Plaintiff and defendants are all of legal age. Interpleader. and Declaratory Relief a. On 1 June 2007. [2] 2. [5] (Sgd. The watch is now in plaintiff’s possession. without knowing who its true owner is. respectfully states that: [1] 1.

executed a Deed of Sale of real estate in favor of the respondent dated _____________. 7 July 2007. a copy of which is attached. Respondent. UMA AGAW. [3] WHEREFORE. 1357 NALI LITO. as follows: (Describe property) covered by TCT No. x -----------------------------------------------. and particularly described. Equity demands that the said Deed of Sale be surrendered and cancelled. as shown by a judgment in Civil Case No. as it is a cloud upon the title of the deceased and his lawful heirs.x PETITION PETITIONER. 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. 4. The same is annotated on the title as the only encumbrance thereon. during his lifetime. The deceased. Action to Quiet (or Remove Cloud on) Title IN RE: QUIETING OF TITLE OVER THE PROPERTY COVERED BY TCT NO. The sale is fictitious and the Deed of Sale is forged. 3. 2468. [2] 2. Petitioner. by counsel. respectfully states that: [1] 1. [5] (Sgd. petitioner respectfully prays that this Honorable Court render judgment in the Estate’s favor by ordering the Deed of Sale surrendered and cancelled and the cloud on Title No. He is the special administrator of the estate of the deceased DAMI LUPA.) JANG GEUN SUK Counsel for Petitioner [Address] PLUS: [6] Verification and Certification against Forum Shopping LEGAL FORMS AND WRITING JANEIT PAJILA 37 . as Special Administrator of the Estate of the deceased DAMI LUPA. 12345 in the Register of Deeds of Makati. 12345 removed.b. 12345 SCA No. [4] Quezon City.

It fails to consider that. 2468 . due to the worsening traffic conditions in Metro Manila.000. 7 July 2007. plaintiff respectfully prays that this Honorable Court grant declaratory relief and declare plaintiff’s rights and duties under the Ordinance.) STRAWBERRY ARMADILLO Counsel for Plaintiff [Address] PLUS: [6] Verification and Certification against Forum Shopping d. [4] Quezon City. Plaintiff is a lawyer who frequently has to dictate important pleadings over the phone while in transit due to the worsening traffic condition. x --------------------------.00 for each offense in addition to impounding of the cellular phone unit. defendant City Council passed Ordinance No. defendant is the City Council of Quezon City.c. Plaintiff. [2] 2. its members may be served with notices at Quezon City Hall. respectfully states that: [1] 1.versus THE CITY COUNCIL OF QUEZON CITY. 2345 making it unlawful to operate cellular phone units while inside a moving vehicle and penalizing any violations with a fine of P1. 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. On 1 August 1999. 4. the duly-constituted legislative body for Quezon City.x COMPLAINT PLAINTIFF. [5] (Sgd. The relevant portions of the Ordinance are. 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. Plaintiff is a Filipino citizen of legal age and resident of Quezon City. Quo Warranto (Caption and title) LEGAL FORMS AND WRITING JANEIT PAJILA 38 Civil Case No. as follows: (Quote the relevant portions) 3. Defendant. [3] WHEREFORE. majority of business is conducted in transit and over cellular phones. by counsel. Action for Declaratory Relief INA API. The Ordinance appears to bar his doing so but plaintiff is unaware of the limits of permissible action under the Ordinance.

(State 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. 7 July 2007.) 3. [4] Quezon City. by counsel.COMPLAINT PLAINTIFF. respectfully states that: [1] 1. [5] (Sgd.)STRAWBERRY ARMADILLO Counsel for the Plaintiff [Address] PLUS: [6] Verification and Certification against Forum Shopping LEGAL FORMS AND WRITING JANEIT PAJILA 39 .) [2] 2. (State that plaintiff has demanded that defendant vacate said office and deliver it to plaintiff but that defendant has unlawfully refused to do so. (State the capacity and address of both plaintiff and defendant.) [3] WHEREFORE. plaintiff respectfully prays that a writ of quo warranto 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.

This is attested to by the following exchange that transpired between Mr. I am a member of the Triple X Village Homeowner’s Association (“Association”) and was formerly a Director and Corporate Secretary of the Association.000. reputation and character are incapable of pecuniary estimation as these are the result of a lifetime’s effort to build a name.III. do hereby state under oath that: 1. Complaint-Affidavit ) ) s. Ingay cannot be allowed to simply go scot-free without bearing the consequences of his acts. MA INGAY. For this reason. of violating Article 358 of the Revised Penal Code (Slander and Oral Defamation). Ingay’s remarks have injured my name. PLEADINGS AND OTHER LEGAL FORMS IN CRIMINAL PROCEDURE A. 5. I am also holding Mr. Complaint-Affidavit and Counter-Affidavit 1.00) in moral LEGAL FORMS AND WRITING JANEIT PAJILA 40 .000. Prior resort to the Barangay conciliation system proved fruitless as Mr. Mr. Consequently. Republic of the Philippines City of Makati COMPLAINT-AFFIDAVIT [1] I. Mr. MA SELAN. residing at 5 Privet Drive. of legal age. 6. with assistance of counsel. Mr.000.s. Makati. Filipino. There is no other person named “Ma Selan” residing at Triple X Village nor is there any other person named “Ma Selan” who has acted as Board Member of the Association. uttered in a public meeting are clearly insulting and defamatory as they malign me and attribute to me a criminal act. maliciously and deliberately uttered defamatory remarks against me during the Board Meeting of the Association on 27 January 2007. nature and predisposition. 4. Ma Ingay’s remarks. calling me a swindler twice over. There is. Ingay’s use of the word “swindled” was deliberate as his explanation and clarification a few utterances thereafter would show. Consequently. reputation and character that my children and their children can be proud to bear. Ingay’s public and defamatory utterance was clearly a reference to me and to no other. Five Hundred Thousand Pesos (P500. Mr. Triple X Village. Ingay and the other members of the Board in attendance: (Quote Exchange) Attached as ANNEX A is a copy of the official transcript of the meeting. character and very person before my peers and fellow homeowners. 3. committed against me when he publicly. and [2] resident of 4 Privet Drive. a copy of which is attached as ANNEX B. Triple X Village. moreover. Ingay’s remarks are also very serious as they cast aspersions on my reputation. Ingay did not retract his remarks. While my name. a “Certification to File Action” was issued by the Barangay Chairperson. Makati. no doubt that Mr. I accuse and hereby charge MR.00) in nominal damages. [3] 2. Ma Ingay liable civilly for defaming me in the amount of One Million Pesos (P1. reputation and character before my neighbors and peers. Mr.

) Investigating Prosecutor LEGAL FORMS AND WRITING JANEIT PAJILA 41 . TO THE TRUTH OF THE FOREGOING.) MA SELAN Complainant-Affiant [5] SUBSCRIBED AND SWORN TO BEFORE ME this 13th day of April 2007. (Sgd.000.00) in exemplary damages.) 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. [4] (Sgd.damages and Five Hundred Thousand Pesos (P500. (Sgd. I have signed this ComplaintAffidavit on 13 April 2007.

2. Counter-Affidavit Republic of the Philippines ) City of Makati ) s.s. COUNTER-AFFIDAVIT Re: I.S. No. 1613 [1] I, MA LABO, of legal age, with 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, which made the Mayor their Honorary Chairman with no direct functions; he has been supporting their activities financially with voluntary contributions. [3] 4. There is no truth to the allegations in MA GULANG’s complaint. There is no factual nor legal basis to charge me with estafa. The Complaint must be dismissed. To rebut and contradict MA GULANG’s 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 was not around. I took a message from her saying that she was a friend of the Mayor and that she was selling Nextel units and if we wanted 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 were able to meet, as a result. 4.3. On that day, Ms. Gulang brought the units to the Mayor’s Office; she met with Mr. Gantso inside the Mayor’s office. They transacted business inside the Mayor’s Office and only passed by my office on their way 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 would 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 LEGAL FORMS AND WRITING JANEIT PAJILA 42

Gantso so that she could just call him directly. But even then, I would still get calls from Ms. Gulang; and when she started to get angry over the telephone, I set up an appointment for Mr. Gantso to meet with her at the Office. 4.6. Thereafter, I would still receive phone calls telling me that Mr. Gantso had yet to pay; I would follow up with Mr. Gantso but he simply gave me this promise that he would pay. 5. It is utterly inexplicable that Ms. Gulang would hold me liable for estafa when all that I did was to refer Ms. Gulang to Mr. Gantso; to a certain extent, I even exerted my best efforts to see that Ms. Gulang was paid due simply to my great embarrassment at the prospect of being accused of referring a person who 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 under 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 (which Ms. Gulang does not even allege and cannot prove); any civil liability should pertain to the Office of the Mayor, not to me. 7. Considering the foregoing, I respectfully submit that there is no prima facie basis to conclude that the crime of Estafa or that any crime at all has been committed. The Complaint against me should, thus, be dismissed. 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

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B. Information and Complaint 1. Information (with Certificate of Preliminary Investigation or Inquest) a. Bigamy (Caption) PEOPLE OF THE PHILIPPINES, Plaintiff, - 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. CONTRARY TO LAW. MA. ECHOSERA 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. MA. ECHOSERA Assistant City Prosecutor Criminal Case No. 00567 For: Bigamy

SUBSCRIBED AND SWORN TO BEFORE ME this 9th day of August 2006 in Quezon City. MA. KURA COTE City Prosecutor Bail Recommended: P10,000.00 LEGAL FORMS AND WRITING JANEIT PAJILA 44

LEGAL FORMS AND WRITING JANEIT PAJILA 45 .

despite opportunity to do so. an Inquest was conducted.00) to the prejudice of said owner.000. there is reasonable ground to believe that the accused has committed the crime of theft and should. CONTRARY TO LAW. ECHOSERA Assistant City Prosecutor SUBSCRIBED AND SWORN TO BEFORE ME this 9th of August 2006 in Quezon City. committed as follows: That on or about 3 July 2006. Theft (Caption) PEOPLE OF THE PHILIPPINES. for this reason. Accused. then 11 years old and without any known address. willfully. KURA COTE City Prosecutor Criminal Case No. the owner. in the City of Quezon and within the jurisdiction of this Honorable Court.versus KLEPTO MANIAC. Plaintiff. x --------------------------------------------.x INFORMATION The Undersigned accuses KLEPTO MANIAC of the crime of Theft. the said accused. with intent to gain. took a gold necklace studded with diamonds valued at One Hundred Thousand Pesos (P100. that based on the complaint and the evidence presented before me without any countervailing evidence submitted by the accused. without force upon things or violence upon persons and without the knowledge and consent of MA ALAHAS. that this Information was with the prior authority of the City Prosecutor. MA. . upon being informed of his rights.b. MA. 00567 For: Theft LEGAL FORMS AND WRITING JANEIT PAJILA 46 . ECHOSERA Assistant City Prosecutor CERTIFICATION AS TO CONDUCT OF INQUEST I hereby certify that the accused was lawfully arrested without a warrant and that. unlawfully and feloniously. MA. thus. refused to waive the provisions of Article 125 of the Revised Penal Code and. be held for said crime.

and finding that her husband was away. commenced directly by overt acts to commit the crime of attempted rape upon her person.versus MAEL SIA. 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. with lewd designs and by means of force and intimidation. x --------------------------------------------.c. CONTRARY TO LAW with the aggravating circumstance of dwelling. the accused did then and there wilfully. the accused seized her from behind. causing the accused to flee from the premises without completing all the acts of execution. ECHOSERA Assistant City Prosecutor PLUS: Certification of Preliminary Investigation or Inquest Criminal Case No. in Quezon City.x INFORMATION The undersigned accuses MAEL SIA of attempted rape committed as follows: That on or about 6 June 2005. Accused. MA. 00567 For: Attempted Rape LEGAL FORMS AND WRITING JANEIT PAJILA 47 . Plaintiff. threw her to the floor. . a married woman. to wit: while SEK SEE was cooking lunch. Attempted Rape (Caption) PEOPLE OF THE PHILIPPINES. raised her skirt. unlawfully and feloniously enter the house of SEK SEE.

which wounds would have been fatal had not timely medical assistance been rendered to the said Vic Tima. an invalid septuagenarian. Accused. directly aim the same firearm at the person of VIC TIMA. . ECHOSERA Assistant City Prosecutor PLUS: Certification of Preliminary Investigation or Inquest LEGAL FORMS AND WRITING JANEIT PAJILA 48 .44 Caliber Magnum pistol. Frustrated Murder (Caption) PEOPLE OF THE PHILIPPINES.versus MAMA MATAY. (Sgd. in Quezon City. CONTRARY TO LAW with the aggravating circumstances of Evident Premeditation.) MA. and. with intent to kill. inflicting on said Vic Tima two (2) wounds on his chest and stomach. x --------------------------------------------. use of firearm and disregard of age. 00567 For: Frustrated Murder That on or about 21 August 2006. at point blank range. the accused did then and there take a loaded . Plaintiff.x INFORMATION The undersigned committed as follows: accuses MAMA MATAY of frustrated murder Criminal Case No. discharge the firearm twice against the person of said Vic Tima.d.

Motion to Quash Information [1] Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 90. Plaintiff. 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.x MOTION TO QUASH [2] THE ACCUSED.C.) JUAN DELA CRUZ Counsel for the Accused [Address] PLUS: LEGAL FORMS AND WRITING JANEIT PAJILA 49 IF TRUE. CONSTITUTE A LEGAL JUSTIFICATION. Accused. WOULD . 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. [6] (Sgd. Even granting said discernment. x -----------------------------------------. In support. 7 July 2007. it is respectfully prayed that the Information against the accused be QUASHED and that the accused be released immediately from detention. Motions 1. 00567 . by counsel. 2. respectfully moves to quash the Information for the crime of theft on the following: [3] GROUNDS 1.versus For: Theft KLEPTO MANIAC. Criminal Case No. [5] Quezon City. There is no allegation that the accused acted with discernment. the accused respectfully states that: ARGUMENT The Information alleges that the accused KLEPTO MANIAC is eleven (11) years old and without any known address. Quezon City PEOPLE OF THE PHILIPPINES. the accused cannot be tried but instead proceeded against under Article 80 of the Revised Penal Code. paragraph 3 of the Revised Penal Code. [4] WHEREFORE. which provides that a minor. IT CONTAINS AVERMENTS WHICH. is exempt from criminal liability. Under Article 12. a person over nine years of age and under fifteen. THIS COURT IS WITHOUT JURISDICTION. unless he acted with discernment.

[7] Request for and Notice of Hearing 2.1. [8] Proof of Service LEGAL FORMS AND WRITING JANEIT PAJILA 50 .

this is certified to by the Sworn Inventory and Return executed by Major Alang Alam. A search was made on the same day. Accused. [5] (Sgd.x MOTION TO QUASH SEARCH WARRANT The ACCUSED. Motion to Quash Search Warrant [1] (Caption) PEOPLE OF THE PHILIPPINES. the leader of the searching team (a copy of which is already part of the records). [4] Quezon City. the Search Warrant is void and must.) MA TAPANG Counsel for Accused [Address] PLUS: 1. certain objects were seized and delivered to the court. Under the law. [7] Proof of Service Criminal Case No. It was served on the accused on 23 July 2006. x ---------------------------------------------. 1122 be QUASHED and all objects seized under its purported authority be declared INADMISSIBLE under the exclusionary rule in Article III. be quashed. Section 3(2) in relation to section 2 of the 1987 Constitution.2. it shall be void. [6] Request for and Notice of Hearing 2. Plaintiff. . 1122 issued by this Honorable Court on and dated 12 July 2006 based on the following considerations: [2] 1. it is respectfully prayed that Search Warrant No. respectfully moves for the quashal of Search Warrant No. 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. Search Warrant No. 2. 00022 For: Libel LEGAL FORMS AND WRITING JANEIT PAJILA 51 . pursuant to said search. by counsel. 1122 is dated 12 July 2006. 25 July 2006. 23 July 2006. thus. Sec. [3] WHEREFORE. Rule 126.versus VIG CHAN. the 11th day from its date.

2. pursuant to Search Warrant No. Criminal Case No. For this reason. The motor vehicle seized does not fall within the property that may lawfully be seized.versus VIG CHAN. 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. 4. respectfully moves for the suppression of objects seized on 23 July 2006. 1122 was served on the 11th day and is. 3. Sec. 1122 was served on the 11th day and is. x ---------------------------------------------. 23 July 2006. Thereafter. this is certified to by the Sworn Inventory and Return executed by Major Alang Alam. “No. it shall be void. Rule 126. A search was made on the same day. Plaintiff. It was served on the accused on 23 July 2006. Under the law. the Search Warrant is void.x MOTION TO SUPPRESS EVIDENCE UNLAWFULLY SEIZED The ACCUSED. it was impounded and kept at the PNP Motor Pool. Motion to Suppress Evidence [1] (Caption) PEOPLE OF THE PHILIPPINES. 5.3. void. the 11th day from its date. pursuant to said search. certain objects were seized and delivered to the court. No valid seizure may be made under a void warrant. Search Warrant No. thus. There is no relation between the motor vehicle and libel. void. On the occasion of the search. 1122 is dated 12 July 2006. . 00022 For: Libel LEGAL FORMS AND WRITING JANEIT PAJILA 52 . 2. Discussion [1] Search Warrant No. the following objects must be suppressed: [list items] [2] The motor vehicle seized does not fall within the property that may lawfully be seized. the searching party also “seized” accused’s green Jaguar XJE with license plate. 1". Search Warrant No. thus. 1122 issued by this Honorable Court dated 12 July 2006. Accused. 1. based on the following considerations: [2] 1. The motor vehicle cannot be subject of the offense as accused is charged with libel. allegedly for being subject of the offense. by counsel. the leader of the searching team (a copy of which is already part of the records).

it is respectfully prayed that all objects seized under the void Search Warrant No. it is prayed that the Green Jaguar XJE with license plate “No.6. the motor vehicle is not mala prohibita that would justify a seizure thereof. 25 July 2006. [7] Proof of Service LEGAL FORMS AND WRITING JANEIT PAJILA 53 .) MA TAPANG Counsel for Accused [Address] PLUS: 1. Moreover. [6] Request for and Notice of Hearing 2. section 3(2) in relation to Section 2 of the 1987 Constitution. Furthermore. 1" be immediately returned to the accused. 1122 be declared INADMISSIBLE under the exclusionary rule in Article III. neither could there be a seizure of evidence in plain view. [4] Quezon City. [3] WHEREFORE. [5] (Sgd.

The Information alleges that he raped the private complainant on 25 December 2005 at his residence in Quezon City. Accused. Quezon City.versus NAKA PIIT. grant the accused reasonable bail. x -----------------------------------------. Other just and equitable reliefs are also prayed for. 7 July 2007. For these reasons. WHEREFORE. He is.x MOTION FOR BAIL [2] THE ACCUSED. 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. Plaintiff. there is no basis to conclude that the accused raped the private complainant as there is less than circumstantial evidence of this fact. entitled to bail as a matter of right. he respectfully submits the following: 1. .)KA DEREE Counsel for the Accused [Address] PLUS: Request for and Notice of Hearing Criminal Case No. The prosecution’s own evidence. respectfully moves to be allowed bail on the ground that the [3] prosecution’s evidence of his guilt is not strong. 00567 For: Murder LEGAL FORMS AND WRITING JANEIT PAJILA 54 . during which the prosecution should be directed to present its evidence to show the strength of its evidence of the accused’s guilt.4. 2. thus. by counsel. (Sgd. and (2) thereafter. two (2) days after the alleged rape. Motion for Bail [1] (Caption) PEOPLE OF THE PHILIPPINES. it is respectfully prayed that the accused be granted: (1) a bail hearing. In support. (b) the medical certificate issued by the NBI doctor (attached as ANNEX B to the Information) after a physical examination of the accused. 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.

00). she pleaded “guilty” to the offense charged herein. Quezon City.2. [2] 2.4. Accused-applicant is of legal age and currently gainfully employed at ASN Broadcasting Corporation located at Timog Avenue. She has not been convicted of any crime against national security or public order.versus RECY DIVIST. Moreover. 968. the accused respectfully submits the following: 1. Plaintiff. 968.3. [3] WHEREFORE. Accused-applicant humbly submits that she possesses all the qualifications and none of the disqualifications enumerated under section 2 of Presidential Decree No. 2. Accused. x ---------------------------------------------. In support of this application. 114878 .1. as amended. specifically: 2. by counsel. to date. 2.x APPLICATION FOR PROBATION THE ACCUSED. consequently. Application for Bail [1] (Caption) PEOPLE OF THE PHILIPPINES. respectfully applies for probation pursuant to the provisions of Presidential Decree No. accused-applicant will commit another crime. 2. She has not previously applied for nor had been previously placed under probation under Presidential Decree No. She has not started to serve her sentence and. On 23 February 2007. are fair. 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. has not filed any Notice of Appeal from the Order of conviction. 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. LEGAL FORMS AND WRITING JANEIT PAJILA 55 Criminal Case No. 968.D. . 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. under the circumstances. accused-applicant does not need any correctional treatment requiring commitment to an institution. just and reasonable in the sound discretion of this Honorable Court. 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. 3 Finally.

(Sgd.Quezon City for Pasig City. [4] Verification 2. 12 March 2007.) JUAN DELA CRUZ Counsel for Accused [Address] PLUS: 1. [5] Request for and Notice of Hearing LEGAL FORMS AND WRITING JANEIT PAJILA 56 .

the amount stated.x FORMAL OFFER OF EVIDENCE THE PROSECUTION.00) which.000. by the undersigned public and private prosecutors. on presentment for payment. the dorsal side of the check with notation “DAIF”. 000011 . Offer of Evidence and Opposition/Comment to Offer 1. the private complainant. respectfully offer their documentary exhibits in support of their case-in-chief: 1. and as part of the testimony of the private complainant. The marked copies of Exhibits A and B are already part of the record.IV. Accused.versus RECY DIVIST. WHEREFORE.000. Exhibit B. his signature–to prove that on the date and time stated in the affidavit. Formal Offer of Evidence Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 90. Criminal Case No. issued by the accused in the amount of One Million Pesos (P1. the signature of accused on face of the check–to prove the issuance of the check. x -----------------------------------------. the sworn statement of ‘Alang Kaso. 2. Plaintiff. 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. and Exhibit A-1. Quezon City PEOPLE OF THE PHILIPPINES. was dishonored for lack of insufficient funds. to prove authorship and the authenticity of the sworn statement. 7 July 2007. the reason for dishonor and the identity of the issuer. MA KUPAL Public Prosecutor Copy furnished: MITCH MCDEERE Counsel for Accused JUAN DELA CRUZ Private Prosecutor LEGAL FORMS AND WRITING JANEIT PAJILA 57 .000. PLEADINGS AND OTHER LEGAL DOCUMENTS COMMON TO CIVIL AND CRIMINAL PROCEDURE A. the accused issued a post-dated check in the amount of One Million Pesos (P1. Exhibit B-1. Exhibit A. Exhibit B-2. the post-dated check dated 30 June 2004.000. Quezon City.00).

x COMMENT ON THE PROSECUTION’S FORMAL OFFER OF EVIDENCE THE ACCUSED. issued by the accused in the amount of One Million Pesos (P1.00). respectfully oppose the Prosecution’s Offer of Evidence for the following reasons: 1. Exhibit A. ACCORDINGLY. x -----------------------------------------. the post-dated check dated 30 June 2004.2. 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. 7 July 2007. Exhibit B-1. KURA COTE Private Prosecutor the LEGAL FORMS AND WRITING JANEIT PAJILA 58 . Criminal Case No.000. Plaintiff. thus. the dorsal side of the check with notation “DAIF”. the sworn statement of ‘Alang Kaso. KUPAL Public Prosecutor MA. the document is hearsay and inadmissible.versus RECY DIVIST. 000011 . be EXCLUDED. Accused. Exhibit B-2.) JUAN DELA CRUZ Counsel for the Accused [Address] Copy furnished: MA. Exhibit B. the private complainant. and Exhibit A-1. and no basis for the presentation of secondary evidence laid. the ACCUSED respectfully submits that Prosecution’s Exhibits are INADMISSIBLE and must.000. 2. by counsel. (Sgd. his signature are INADMISSIBLE because the private complainant was never presented to authenticate the document or subjected to cross-examination. Quezon City. thus. Comment/Opposition to Offer PEOPLE OF THE PHILIPPINES.

. by counsel. 2. The proof of the negative element is indispensable to proof of a violation of PD 1866. the offense is not proven.e. It is only in the event that the prosecution. he must. Accused. Without proof of this negative element. The effect of this presumption is that it entitles the accused to not say anything in his defense and places the burden directly on the prosecution to prove everything relative to his guilt. x ---------------------------------------. the gravamen of the offense is unauthorized possession of a firearm. this means that the prosecution must prove that the accused had no legal authority to possess any firearm. 13 April 2007. Quezon City. absence of a license.. the Prosecution’s Evidence on the to adduce sufficient evidence of his innocence and shift the burden of Criminal Case No. the crime is not proven. Under the Constitution.1. Criminal cases (Caption) PEOPLE OF THE PHILIPPINES. i. Concretely. 2.B. JANG GEUN SUK Counsel for the Accused [Address] PLUS: Request for and Notice of Hearing LEGAL FORMS AND WRITING JANEIT PAJILA 59 . 3. 2. 007 For: Violation of PD 1866 1. The prosecution has failed to adduce sufficient evidence of guilt such as would shift the burden of proof.x DEMURRER TO THE PROSECUTION’S EVIDENCE THE ACCUSED. Plaintiff. be acquitted. Thus. thus.versus ANAKIN SKYWALKER. Absent proof of the negative element. The prosecution has failed to show that the accused had no license to carry a firearm. The accused is charged with violation of PD 1866. the prosecution must rely on the strength of its evidence and not wait for the accused to offer any defense. with respectfully submits this Demurrer to ground that the prosecution has failed guilt to overcome the presumption of proof: leave of court previously obtained. has adduced sufficient evidence of guilt that the burden of proof shifts to the accused. WHEREFORE. The accused is innocent. the accused is presumed to be innocent until proven guilty. after resting its case.2. Demurrer to the Evidence 1. the accused respectfully prays that the Information against him be DISMISSED and that he be ACQUITTED of the crime charged.

defendant respectfully prays that the Complaint against her be DISMISSED. respectfully submits this Demurrer to the Evidence because plaintiff has failed to prove entitlement to his claims by a preponderance of evidence: 1. plaintiff has failed to prove his claims by a preponderance of evidence and defendant is entitled to a dismissal of the Complaint against her.2. 3. Consequently. (b) the extent of the obligation under the contract. This action seeks to collect a sum of money arising from a contract. Plaintiff. after resting his case. (c) the demandability of the obligation under the contract and (d) defendant’s liability for the obligation and damages. Civil cases (Caption) ANAKIN SKYWALKER. Plaintiff. Quezon City. (Sgd.) JUAN DELA CRUZ Counsel for Defendant [Address] PLUS: Request for and Notice of Hearing LEGAL FORMS AND WRITING JANEIT PAJILA 60 . 13 April 2007. Defendant.x DEMURRER TO THE EVIDENCE DEFENDANT. WHEREFORE.versus PADME AMIDALA. x ---------------------------------. by counsel. 000909 . 2. Civil Case No. has failed to: (a) prove the authenticity of the contract. with leave of court previously sought and granted.

13 April 2007.C. DAYA COH Counsel for Defendant Civil Case No. Rizal. . (Sgd.) JUAN DELA CRUZ Counsel for Plaintiff [Address] Copy furnished: MA.x NOTICE OF LIS PENDENS THE REGISTER OF DEEDS Antipolo City. Quezon City. Plaintiff. Accordingly. please record this notice on the title.versus ALANG LUPA. Rizal Province Please take notice that a parcel of land covered by TCT No 1234 located in Antipolo. 007 For: Reconveyance LEGAL FORMS AND WRITING JANEIT PAJILA 61 . Antipolo DAMI LUPA. RESPECTFULLY SUBMITTED. above-named plaintiff. 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. x ----------------------. Notice of Lis Pendens Republic of the Philippines 4th Judicial Region REGIONAL TRIAL COURT Branch 71. Defendant.

RESPECTFULLY SUBMITTED.x ENTRY OF APPEARANCE THE BRANCH CLERK OF COURT Regional Trial Court Branch 101. Defendant. x -------------------------------. in this case. Appearance as Counsel Republic of the Philippines REGIONAL TRIAL COURT National Capital Judicial Region Branch 101. Quezon City ANAKIN SKYWALKER. Pasig City WITH MY CONFORMITY: (Sgd. 13 April 2007. with her express conformity as indicated below. 1357 For: Legal Separation LEGAL FORMS AND WRITING JANEIT PAJILA 62 . Henceforth kindly address all pertinent notices to the undersigned at the address given below. Quezon City. .) JUAN DELA CRUZ No.versus PADME AMIDALA. Quezon City Please enter the appearance of the undersigned as counsel for defendant Padme Amidala. 1. Plaintiff. (Sgd. Imzadi Place Tatooine.) PADME AMIDALA Copy furnished: MA DAYA COH Civil Case No.D.

Pasig City WITH MY CONFORMITY: (Sgd. Cloud City. Civil Case No. Quezon City Please make of record the WITHDRAWAL of the undersigned as counsel for plaintiff ANAKIN SKYWALKER.x WITHDRAWAL OF APPEARANCE THE BRANCH CLERK OF COURT Regional Trial Court Branch 101.E. 1357 For: Legal Separation 2. Henceforth kindly address all pertinent notices to plaintiff at his address given in the Complaint. RESPECTFULLY SUBMITTED. Withdrawal as Counsel WITHOUT conformity of client (Caption) ANAKIN SKYWALKER. in this case.) JUAN DELA CRUZ 1 Imperial Palace. Plaintiff. Defendant. 7 July 2007. . with his express conformity as indicated below. 1357 LEGAL FORMS AND WRITING JANEIT PAJILA 63 . Withdrawal as Counsel (Caption) ANAKIN SKYWALKER.versus PADME AMIDALA. x -------------------------------. Plaintiff.) ANAKIN SKYWALKER Civil Case No. Quezon City. (Sgd. Withdrawal as Counsel 1.

x -------------------------------. Quezon City. for which reason the express conformity of plaintiff cannot be obtained. Henceforth kindly address all pertinent notices to plaintiff at his address given in the Complaint.x For: Legal Separation WITHDRAWAL OF APPEARANCE THE BRANCH CLERK OF COURT Regional Trial Court Branch 101. RESPECTFULLY SUBMITTED.) JUAN DELA CRUZ 1 Imperial Palace.versus PADME AMIDALA.. Quezon City Please make of record the WITHDRAWAL of the undersigned as counsel for plaintiff ANAKIN SKYWALKER due to irreconcilable professional differences with plaintiff. 7 July 2007. Cloud City. Defendant. Pasig City LEGAL FORMS AND WRITING JANEIT PAJILA 64 . (Sgd.

x SUBSTITUTION OF COUNSEL THE UNDERSIGNED respectfully enters his appearance as counsel for defendant Padme Amidala in substitution of former counsel Darth Maul. Quezon City. RESPECTFULLY SUBMITTED. Henceforth. LEGAL FORMS AND WRITING JANEIT PAJILA 65 . as shown by her express conformity below.) PADME AMIDALA Civil Case No. . Pasig City WITH MY CONFORMITY: (Sgd. kindly address all pertinent notices to the undersigned at the address given below. Notice of Appeal Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 1. 1357 For: Legal Separation G. Defendant. JUAN DELA CRUZ Counsel for Defendant 2 Corruscant Place Tatooine Road. Manila TALO NAN. Plaintiff.versus PADME AMIDALA.F. x -------------------------------. 7 July 2007. Substitution of Counsel (Caption) ANAKIN SKYWALKER.

versus PANA LO. respectfully appeals to the Court of Appeals the Decision of this Honorable Court dated 6 July 2006. Civil Case No. Defendant. 17 July 2006. by counsel. x------------------------.x NOTICE OF APPEAL PLAINTIFF. (Sgd. for being contrary to law and the evidence presented. a copy of which he received on 16 July 2006.Plaintiff. 00222 .) JUAN DELA CRUZ Counsel for Plaintiff [Address] Copy furnished: MITCH CATHEE Counsel for Defendant LEGAL FORMS AND WRITING JANEIT PAJILA 66 . Quezon City for Manila.

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. by counsel. 7 July 2007. subject of this petition. Petitioner. Petitioner is the mother of the minors Luke and Leia Skywalker.x PETITION PETITIONER. PLEADINGS AND LEGAL DOCUMENTS ON DOMESTIC CASES AND SPECIAL PROCEEDINGS A. 3. present the minor children personally before the Court on a date and time it chooses. as their mother. who were born out of the valid marriage between petitioner and respondent Anakin Skywalker. The marriage failed and petitioner has been living separately from respondent since 2004. 111334 PADME AMIDALA. Consequently. abducted the minor children and has kept them incommunicado and out of petitioner’s reach. unknown to petitioner.V. respectfully states that: 1. Petition for Habeas Corpus Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 191. Makati IN RE: PETITION FOR HABEAS CORPUS OF THE MINORS LUKE AND LEIA SKYWALKER SP No. Quezon City. x -----------------------------------------. JANG GEUN SUK Counsel for Petitioner [Address] PLUS: Verification and Certification against Forum Shopping LEGAL FORMS AND WRITING JANEIT PAJILA 67 . custody of the minors is naturally presumed to belong to petitioner. Being below seven (7) years of age. Respondent. WHEREFORE. and thereafter. 2. Sometime in February 2007. respondent. respondent’s refusal to allow petitioner to regain custody over the minors is unlawful and unjustified. ANAKIN SKYWALKER.

2. They have no legitimate children of their own and desire to jointly adopt a minor named ANAKIN SKYWALKER. x -----------------------------------------. 10 years old. The parents of the minor are not insane. 3. 111334 DARTH VADER and PADME AMIDALA. intemperate and are in full possession of civil capacity. Petition for Adoption IN RE: PETITION FOR ADOPTION OF ANAKIN SKYWALKER SP No. 7 July 2007. as shown by their statement. they are also morally qualified to bring up and educate the said minor. they have expressly given their written consent to the adoption. With full knowledge of petitioners’ intention. by counsel. Petitioners are qualified to adopt the minor and are financially capable of supporting the minor. a copy of which is attached as ANNEX A. 4. 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.) MASTER YODA [Address] PLUS: Verification and Certification against Forum Shopping LEGAL FORMS AND WRITING JANEIT PAJILA 68 . WHEREFORE. and residents of __________.B.x PETITION PETITIONERS. Petitioners. the child of herein petitioners and that his/her surname be changed to that of petitioners. (Sgd. respectfully state that: 1. the legitimate child of _________________. Petitioners are husband and wife. Quezon City. they have not abandoned the minor child. both of legal age.

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. the parties had attempted formal and informal counseling sessions all of which proved unproductive as respondent proved resistant and. thus.C. she may be served with notices and other pertinent processes through counsel at [address of counsel]. In compliance with jurisdictional requirements. a copy each of the birth certificates of the minor children is attached as ANNEX B. prior to this resort. 8. Petitioner and respondent are currently separated in fact and have been so since May 2001. of legal age and married to respondent. 2. Respondent is a Filipino citizen. 4.” The psychological make-up of petitioner and respondent is explained in greater detail in the Clinical Assessment Report (“Report”) dated 28 December 2006. Clinical Psychologist [state name]. even hostile to these efforts. Their minor children are in petitioner’s custody and are being supported by her financially and emotionally. it was. LEGAL FORMS AND WRITING JANEIT PAJILA 69 . respondent refuses to agree to any sober and productive discussion with petitioner and is always highly emotional and angry. on the other hand. The reason for the continuing separation in fact is the breakdown of the marriage due to both petitioner’s and respondent’s mutual psychological incapacity to fulfill and discharge their respective marital obligations to each other. 7.20 Schizoid Personality Disorder with narcissistic features” which is described as “grave. they have [state number of children. impracticable to secure a psychological report and profile of respondent. currently employed at [state employer] and married to petitioner. respectfully states that: 1.1 Partner Relational Problem and is said to have “Masochistic Personality Disorder” or “301. incurable and has antecedents. Petitioner and respondent were married on [date] and out of this marriage. by counsel. The mutual psychological incapacity of the parties to remain married to each other appears to be incurable. respective ages]. C and D. of legal age. should this become material. at times. petitioner submitted herself to a psychological and clinical assessment by a trained professional. Petitioner is a Filipino citizen. Petition for Declaration of Nullity of Marriage with Application for Provisional Orders [Caption and Title] PETITIONER.9 Personality Disorder Not Otherwise Specified”. He may be served with summons and other pertinent orders and processes of this Court at [state address] 3. respectively. Petitioner’s psychological incapacity is described in clinical terms as being consistent with a V61. Despite several attempts. the assessment given by the psychologist of respondent’s psychological make-up is that he has a “301. A copy of the Marriage Contract executed by petitioner and respondent is attached as ANNEX A. 6. a copy of which is attached as ANNEX E. which existed at the time of the marriage in 1998 but manifested itself well into the marriage 5. For purposes of this petition.

save for exceptional circumstances which do not exist in this case. [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. 10. Petitioner cannot. ordering the dissolution of the conjugal partnership of gains. Petitioner submits that. 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. be directed to give support to his children in the amount of (state amount). however. after trial. (Sgd.9. Quezon City. 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. despite the parties’ mutual psychological incapacity to remain married to each other. subject to any adjustments that may be made based on changing earning capacity as well as needs. the interests of the children are best served by having them remain in her custody. by this token. and [2] Awarding permanent custody of the children to petitioner. under the law. thus. judgment be rendered in her favor by declaring petitioner to be psychologically incapacitated to comply with the essential obligations of her marriage to respondent. with visitation rights extended to respondent. with express acknowledgement of respondent’s visitation rights. 7 July 2007. thus -[1] Declaring the marriage between petitioner and respondent a nullity and. WHEREFORE.) MA. COLITE Counsel for the Petitioner [Address] PLUS: Verification and Certification against Forum Shopping LEGAL FORMS AND WRITING JANEIT PAJILA 70 . The common property of petitioner and respondent is insufficient for the support of the children. All of the children are minors and. 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). Petitioner also prays that. Respondent must. All other just and equitable reliefs are also prayed for. children under seven (7) years of age shall not be separated from the mother.

No. Petitioner is a Filipino citizen and the widow of the deceased.. 555. Marinara Subdivision. both of whom are residing at No. The handwriting may be attested to as his by his secretary of long standing. 3. x -----------------------------------. by counsel. 555.x PETITION PETITIONER. Quezon City and cash amounting to Fifty Thousand Pesos (P50. 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.. (Sgd. Tuna Road. having previously executed a holographic will in his own handwriting and in a language known to him. On 16 August 2006.) ASSAR TALLO Counsel for the Petitioner [Address] PLUS: Verification and Certification against Forum Shopping LEGAL FORMS AND WRITING JANEIT PAJILA 71 . Petitioner. 2. PABLING SIA JR. A copy of the will is attached as ANNEX A. WHEREFORE. respectfully states that: 1. The deceased’s only heirs are herein petitioner and their son.000). 7 July 2007. 2. he had no debts. Quezon City. The deceased left a house and lot located at No. Tuna Road. San Juan RE: PROBATE OF THE HOLOGRAPHIC WILL OF PABLING SIA. PABLING SIA died. Petition for Probate of a Holographic Will Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 30. Marinara Subdivision. TOM CRUZ.D. SP PROC. 0023 PALING KERA. Quezon City.

and resident of Naboo. do hereby name. and hereby ratifying and confirming all that she may do by virtue of these presents. to be my true and lawful Attorney-in-Fact and in my name.VI. IN WITNESS WHEREOF.) JUAN DELA CRUZ Principal SIGNED IN THE PRESENCE OF: (Sgd. of legal age.) R2D2 (Sgd. and resident of Tatooine. DEEDS. Special Power of Attorney SPECIAL POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS: I. CONTRACTS AND OTHER CORPORATE LEGAL DOCUMENTS A.) C3PO Acknowledgment B. JUAN DELA CRUZ. I have signed this Special Power of Attorney this 7 July 2007 at Tatooine. constitute and appoint PADME AMIDALA. 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. of legal age. (Sgd. General Power of Attorney GENERAL POWER OF ATTORNEY LEGAL FORMS AND WRITING JANEIT PAJILA 72 .

I have signed this instrument this 7 July 2007 at Tatooine. constitute and appoint PADME AMIDALA to be my true and lawful attorney-in-fact. 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. IN WITNESS WHEREOF. OBI WAN KENOBI. 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. for me and in my name. do hereby name.) R2D2 (Sgd.) OBI WAN KENOBI Principal SIGNED IN THE PRESENCE OF: (Sgd.) C3PO Acknowledgment LEGAL FORMS AND WRITING JANEIT PAJILA 73 . of legal age.KNOW ALL MEN BY THESE PRESENTS: I. and resident of Tatooine. to do and perform the following acts. (Sgd. place and stead.

2.1. To pay the rentals on or before the fifth day of each month. 2. without need of demand at the residence of LESSOR. and ALANG BAHAY. having acknowledged the same before me as their own free and voluntary act and deed. signed on each and every page by the parties and their instrumental witnesses. 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. 2. To keep the premises in good and habitable condition.2. DAMI BAHAY Lessor With my consent: ASA WA Acknowledgment BEFORE ME. Makati City covered by Tax Declaration No. ____________ issued at/on CTC No. of legal age. 001 (Makati City Assessor’s Office) for a period of TWELVE (12) MONTHS from signing of this contract. making the necessary repairs and painting inside and outside the house. single and resident of Quezon City (LESSEE). surrendering ownership over such improvements and alterations to the LESSOR upon expiration of this lease.C. married to ASA WA. The LESSEE covenants. ____________ issued at/on known to me to be the same persons who executed the foregoing instrument. the parties have signed this contract on the date and the place first mentioned. In consideration of a monthly rental of FIVE THOUSAND PESOS (P5.00) and the covenants made below. the LESSOR hereby LEASES to the LESSEE an apartment located at 199 San Antonio Village. IN WITNESS WHEREOF.3. denominated as a Contract of Lease consisting of __ pages. with their respective CTC details indicated below: th ANG BAHAY Lessee DAMI BAHAY ALANG BAHAY CTC No. personally appeared on the 7 of July 2007. the following persons. of legal age. as follows: 2.000. LEGAL FORMS AND WRITING JANEIT PAJILA 74 . witness now my hand and seal on the date and place mentioned above. TO THE TRUTH OF THE FOREGOING. a Notary Public for Makati City. WITNESSETH that: 1. Contract of Lease CONTRACT OF LEASE KNOW ALL MEN BY THESE PRESENTS: This Agreement made and entered into at Makati this 7th day of July 2007 by and between DAMI BAHAY. (LESSOR) and resident of Makati City.

2007 PTR No. 0000111/1/05/99.N. Makati City Doc. Page No.O. LEGAL FORMS AND WRITING JANEIT PAJILA 75 . Book No. No. TARIO Until December 31. Series of 2007.

Metro Manila. SR. I give and bequeath to my children __________. the following properties. __________. PALING KERA. violence. IN WITNESS WHEREOF. bequeathing my house and lot located at No. married to PALING KERA. the language which is known to me.) PABLING SIA. Tuna Road. now actually residing at San Juan.. Marinara Subdivision. and not acting under influence. PABLING SIA JR. PABLING SIA. in equal shares. SR. SR. (Sgd. KNOW ALL MEN BY THESE PRESENTS: I. Holographic Will San Juan. And I hereby declare that: I. whatsoever and wheresoever located: (Description of property) III. (Sgd. declare this to be my Last Will and Testament which I have caused to be written in English. Notarial Will LAST WILL AND TESTAMENT of PABLING SIA. Batangas. a native of Lipa City. real and personal.. being of sound and disposing mind and memory. and __________. Metro Manila 7 July 2007 I hereby execute this holographic will. I designate _______________ as the sole executor of this Last Will and Testament. LEGAL FORMS AND WRITING JANEIT PAJILA 76 . Quezon City to my son. 555. fraud or intimidation of whatever kind. in my handwriting and in the English language which I know how to read and write. Metro Manila.000) to my spouse. and cash amounting to Fifty Thousand Pesos (P50.) PABLING SIA SR. I have set my hand this 7th day of July 2007 in San Juan.D. The following are my children and their addresses. (Name of children and addresses) II. of legal age. E.

on 6 July 2006. as his/her last will and testament and has signed the same and every page thereof. (Sgd. and they respectively acknowledged to me that they signed the same as their own free act and deed. in turn. SAKSI 1 (Witness). including the page in which this acknowledgment is written. This Will consists of ___ pages. on the left margin. on 6 July 2006. year and place written. SAKSI 1 SAKSI 2 SAKSI 3 Residence Residence Residence G. the undersigned witnesses. _______________ LEGAL FORMS AND WRITING JANEIT PAJILA 77 . TARIO Notary Public Until __________________ PTR No. whose residences are stated opposite our respective names. personally appeared: th PABLING SIA. O. SAKSI 1 (Witness). at his/her request have witnessed and signed the same and every page thereof. (Testator). with Valid Identification Document _______ issued by (official agency). in the presence of the testator and in the presence of each other. with Valid Identification Document _______ issued by (official agency). on 6 July 2006. 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. 2007.F. with Valid Identification Document _______ issued by (official agency). I have set my hand the day. Acknowledgment of a Notarial Will JOINT ACKNOWLEDGMENT BEFORE ME. the first as testator and the last three as instrumental witnesses. on 6 July 2006. Philippines. this 7 day of July. all known to me to be the same persons who signed the foregoing Will. Attestation Clause for a Notarial Will ATTESTATION CLAUSE WE. with Valid Identification Document _______ issued by (official agency). SAKSI 2 (Witness).) N. IN WITNESS WHEREOF. SR. in our joint presence and we. Notary Public for and I the City of San Juan. on the left margin. 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.

Issued at ______________ On ___________________ Doc. Series of 2007. Book No. LEGAL FORMS AND WRITING JANEIT PAJILA 78 . Page No. No.

the said DONOR. situated in _________________. 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. for the purpose of giving full effect to this donation. transfers and conveys. of legal age. by these presents. Philippines. the above described real property with all the buildings and improvements thereon. ____ of the land registry of _____________. and more particularly described in Original/Transfer Certificate of Title No. of legal age. single/married.H. That the DONOR does hereby state. and does hereby express gratitude for the kindness and liberality of the DONOR. the DONOR and the DONEE have signed this deed on 7 July 2007 and at Quezon City. and resident of _______________ (“Donor”) in favor of DAMI UTANG. That the DONEE does hereby accept this donation of the abovedescribed property.)MIRON 2 PLUS: Acknowledgment LEGAL FORMS AND WRITING JANEIT PAJILA 79 . unto said DONEE. by way of donation. free from all liens and encumbrances. 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. his/her heirs and assigns. LALIM BULSA Donor ACCEPTED: DAMI UTANG Donee SIGNED IN THE PRESENCE OF: (Sgd.) MIRON 1 (Sgd. IN WITNESS WHEREOF. made and executed by LALIM BULSA. Donation Inter Vivos DEED OF DONATION KNOW ALL MEN BY THESE PRESENTS: This Deed of Donation. single/married and resident of _________________ (“DONEE”) WITNESSETH: That the DONOR is the owner of that certain real property with the buildings and improvements thereon.

Done this 7th day of July 2007 at Quezon City. whether for unpaid subscriptions. of legal age. 5. 3. administrators and other successorsin-interest. The principal shall save the nominee free and harmless from any liability.) UZI 2 PLUS: Acknowledgment LEGAL FORMS AND WRITING JANEIT PAJILA 80 . the nominee shall deliver the same to the principal and whoever the latter may designate. Accordingly. 2. that may arise as a result of the nominee’s holding title to the subject shares for and on behalf of the principal. stock or property. As nominee. 4. 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. whether cash. executors. GEORDI LA FORGE. Acknowledgment of Nominee Status with Assignment of Shares ACKNOWLEDGMENT OF NOMINEE STATUS WITH ASSIGNMENT OF SHARES I. and with office address at __________. accordingly. GEORDI LA FORGE Nominee WITH MY CONFORMITY: WILLIAM RIKER Principal WITNESSES: (Sgd.) UZI 1 (Sgd.I. This acknowledgment of nominee status shall bind the nominee’s heirs. I hereby unequivocally confirm that the Principal is the exclusive and absolute owner of the subject shares. 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. accruing on the subject share shall be for the account and benefit of the principal. Director’s 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. rights and other privileges. (“Nominee”). taxes or otherwise. The nominee hereby assigns. (“the Corporation”). 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.

. as may prove to be beneficial to the corporation in his own opinion and determination... at which meeting a quorum was present and obtained throughout. with the same office address given above. Approved and adopted this 7th day of July. DEANNA TROI Corporate Secretary ATTESTED: JEAN-LUC PICARD President PLUS: Jurat K. IN WITNESS WHEREOF. to LEGAL FORMS AND WRITING JANEIT PAJILA 81 ..J. as Chairperson and Chief Executive Officer of Enterprise Holdings be authorized. the same may be relied upon until a written notice to the contrary is issued by the corporation.. the following resolution(s) was (were) unanimously approved and adopted: RESOLVED. do hereby certify that under oath that: 1. amended or in any manner modified and accordingly. Authority to Act Board Resolution No. (Name of Directors) 2. that . Board Resolutions 1... by a vote of stockholders representing more than 2/3 of the subscribed and paid up capital stock. that Mr.. 2.. to enter into any and all transactions with the representatives of the Ferengi Trade Federation. on the basis of the corporate records. ___ RESOLVED... The foregoing resolution has not been revoked. Philippines. Secretary’s Certificate SECRETARY’S CERTIFICATE I. (“corporation”). with office address at __________________.. DEANNA TROI.. Increase in number of directors and necessary amendment to the Articles of Incorporation Board Resolution No.. 3.. as he is hereby authorized. ___ RESOLVED. of legal age. I am the Corporate Secretary of ENTERPRISE HOLDINGS INC. At a meeting of the Board of Directors of the corporation held on ___________.. 2007 at Makati City... a corporation duly organized and existing under Philippine laws. I have set my hand to this certification on ____ at ______________. Jean-Luc Picard.

Philippines. Approved and adopted this 7th day of July.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. 2007 at Makati City. (Name of Directors) LEGAL FORMS AND WRITING JANEIT PAJILA 82 .

The assignor hereby irrevocably constitute. It is. for and in consideration of the sum of ____________________ Pesos (P_____). transfer and convey unto DAMI LUPA. IN WITNESS WHEREOF. however. of legal age.) MIRON 2 PLUS: Acknowledgment LEGAL FORMS AND WRITING JANEIT PAJILA 83 . and resident of ______________. 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. title. Filipino and resident of ________________. including advances due from said corporation. understood that the assignee shall assume any and all unpaid subscription on the said shares.L. Deed of Assignment DEED OF ASSIGNMENT KNOW ALL MEN BY THESE PRESENTS: I. all his/her rights. ownership and interest over its subscription to One Hundred Thousand (100. the assignor has signed this deed on 7th day of July. DAMI SHARES.000) shares of the capital stock of _________ Corporation. DAMI SHARES Assignor SIGNED IN THE PRESENCE OF: (Sgd. 2007 at the City of Manila. likewise of legal age. cede.) MIRON 1 (Sgd. receipt of which is hereby acknowledged do hereby assign.

as indicated on the face of the title) of which I am the registered owner in fee simple. specify metes and bounds of the property/ies with approximate area thereof. Filipino. If vendor is married. and resident of _________________________. ______. paid to me today by MA GU LANG. the Deed must also indicate this. issued by the Register of Deeds of Makati City. Filipino. DEED OF ABSOLUTE SALE KNOW ALL MEN BY THESE PRESENTS: I. 2007 at Makati City. IN WITNESS WHEREOF. TRANSFER and CONVEY absolute and unconditionally unto said MA GU LANG that certain parcel(s) of land. then add the following:] With my consent: ASA WA Vendor’s Wife SIGNED IN THE PRESENCE OF: (Sgd.M. MA YA MAN Vendor [Note: if vendor is married. MA YA MAN. thus. and more particularly described as follows: (Technical Description of property/ies. marital consent must be secured. It is hereby mutually agreed that the vendee shall bear all expenses for the execution and registration of this deed of sale. single and resident of ________________ do hereby SELL. Deed of Sale of Registered Land (unilateral) Republic of the Philippines ) Makati City ) s.) MIRON 1 (Sgd. I have signed this deed this 7th day of July.s. together with the buildings and improvements thereon situated in the City of Makati. single.) MIRON 2 PLUS: Acknowledgment LEGAL FORMS AND WRITING JANEIT PAJILA 84 . for and in consideration of the amount of _______________________. my title thereto being evidenced by Transfer (or Original) Certificate of Title No.

the permanent improvements. Filipino. the page number of the assessment of each property for current year or years when registration is made. that the permanent improvements existing thereon consist of _________ (if none. situations and boundaries. IN WITNESS WHEREOF. for and in consideration of the amount of __________. the parties hereto have agreed to register this instrument under the provisions of Sec. as amended. and the buildings and/or improvements . MA YA MAN Vendor [Note: if vendor is married.) MIRON 1 (Sgd. together with the buildings and improvements thereon situated in the City of Makati. then add the following:] With my consent: ASA WA Vendor’s Wife SIGNED IN THE PRESENCE OF: (Sgd. what they consist of. single. 2007 at Makati City. single and resident of _______________________ do hereby SELL. marital consent must be secured. If vendor is married. and more particularly described as follows: (Description: state the nature of each piece of land and its improvements. that the land is assessed for the current year at P______________ as per Tax Declaration No. at P____________ as per Tax Declaration No. thus. I have signed this deed this 7th day of July. and if they are. whether or not the boundaries are visible on the land by means of monuments or otherwise. the Deed must also indicate this. not having been registered under Act No. MA YA MAN.N. 496 nor under the Spanish Mortgage Law. Filipino. if any.s. and resident of _________________________. TRANSFER and CONVEY absolutely and unconditionally unto said MA GU LANG that certain parcel(s) of land. state so). _________. __________.) MIRON 2 LEGAL FORMS AND WRITING JANEIT PAJILA 85 . of the City Assessor of Makati. 194 of the Revised Administrative Code. paid to me today by MA GU LANG. area in square meters. The above described real estate. 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 _______________. Deed of Sale of Unregistered Land (unilateral) Republic of the Philippines ) Makati City ) s. DEED OF ABSOLUTE SALE KNOW ALL MEN BY THESE PRESENTS: I.

PLUS: Acknowledgment LEGAL FORMS AND WRITING JANEIT PAJILA 86 .

Provided. hereby reserves the right to REPURCHASE. of legal age. with residence at ____________ (VENDEE). situated in the City of Makati. The VENDOR. IN WITNESS WHEREOF. to him paid by VENDEE and receipt of which is acknowledged. married to ASA WA. and more particularly described. and the VENDEE.O. MA YA MAN Vendor With my marital consent: consent: ASA WA MA GU LANG Vendee With my marital BA TAPA SIGNED IN THE PRESENCE OF: (Sgd. that if the VENDOR shall fail to exercise his right to repurchase as herein granted within the period provided. the property with all the buildings and improvements thereon. without need of a new Deed of Absolute Sale. with residence at ___________________ (VENDOR). free from all liens and encumbrances whatsoever. TRANSFER and CONVEY under pacto de retro unto the said VENDEE. then this conveyance shall become absolute and irrevocable. however. his heirs and assigns. Filipino.and MA GU LANG. I have signed this deed this 7th day of July.) MIRON 1 LEGAL FORMS AND WRITING JANEIT PAJILA 87 . subject to the requirements of law regarding consolidation of ownership of real property.s. for and in consideration of the amount of _________________ Pesos (P_____). DEED OF SALE WITH PACTO DE RETRO This Deed of Sale with Pacto de Retro made and executed by and between: MA YA MAN. in executing this conveyance. Filipino. of legal age. 2007 at Makati City. does hereby SELL. 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____). 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. WITNESSETH: That– The VENDOR is the absolute owner of a certain parcel of land with all the buildings and improvements thereon. . The VENDOR. in accepting the same. Deed of Sale with Pacto de Retro (bilateral) Republic of the Philippines ) Makati City ) s. married to BA TAPA.

(Sgd.) MIRON 2 PLUS: Acknowledgment

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88

P. Deed of Repurchase of land sold under Pacto de Retro Republic of the Philippines ) Makati City ) s.s. DEED OF RESALE KNOW ALL MEN BY THESE PRESENTS: 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 [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: BA TAPA Vendor’s Wife SIGNED IN THE PRESENCE OF: (Sgd.) MIRON 1 (Sgd.) MIRON 2 PLUS: Acknowledgment

LEGAL FORMS AND WRITING JANEIT PAJILA

89

Q. Deed of Sale with Mortgage Republic of the Philippines ) Makati City ) s.s. 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 ___________________ (VENDORMORTGAGEE), - and MA GU LANG, Filipino, of legal age, married to BA TAPA, with residence at ____________ (VENDEEMORTGAGOR); 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 latter’s 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 VENDORMORTGAGEE, 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. IN WITNESS WHEREOF, I have signed this deed this 7th day of July, 2007 at Makati City. MA YA MAN Vendor MA GU LANG Vendee 90

LEGAL FORMS AND WRITING JANEIT PAJILA

) MIRON 2 PLUS: Acknowledgment LEGAL FORMS AND WRITING JANEIT PAJILA 91 .) MIRON 1 (Sgd.With my consent: ASA WA Vendor’s Wife With my consent: BA TAPA Vendee’s Wife SIGNED IN THE PRESENCE OF: (Sgd.

his title thereto being evidenced by Transfer (or Original) Certificate of Title No. That the ASSIGNEE does hereby accept this assignment in full payment of the above-mentioned debt of ______________ Pesos (P_________). DAMI UTANG Assignor With my marital consent: ALANG MALAY Assignor’s Wife PLUS: Acknowledgment DAMI LUPA Assignee BIL MOKO Assignee’s Wife LEGAL FORMS AND WRITING JANEIT PAJILA 92 . the parties have signed this Deed on 7 July 2007 at Makati City. made and executed by and between DAMI UTANG. Filipino. married to BIL MOKO. Filipino. 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. situated in ___________. of legal age. with residence at _____________ (ASSIGNOR) and DAMI LUPA. and more particularly described as follows: (Description of property assigned) of which real estate the ASSIGNOR is the registered owner. married to ALANG MALAY. with residence at _______________ (ASSIGNEE). IN WITNESS WHEREOF. ____________ of the Register of Deeds of _____________. transfer and convey unto the ASSIGNEE that certain real estate with all the buildings and improvements thereon.R. Dacion en Pago (Deed of Assignment of Real Estate in payment of debt) DEED OF ASSIGNMENT KNOW ALL MEN BY THESE PRESENTS: This Deed of Assignment. of legal age.

CHATTEL MORTGAGE KNOW ALL MEN BY THESE PRESENTS: That I. 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. and YAMAN NYA. : 00000001111. DAMI KOTSE Affidavit of Good Faith We severally swear that DAMI KOTSE. granted to me by YAMAN NYA. to be paid one (1) year from date hereof. racing green. it shall continue in full force and effect and may be foreclosed in accordance with law. otherwise. YAMAN NYA DAMI KOTSE Signed in the presence of: UZI 1 PLUS: Acknowledgment UZI 2 LEGAL FORMS AND WRITING JANEIT PAJILA 93 . : BMW 738i (1998). more particularly described as: Model/Make No. mortgagee. being evidenced by Registration Certificate of Motor Vehicle No. have transferred and conveyed by way of chattel mortgage unto said YAMAN NYA. : 00000001111. mortgagor.00). ______ issued in my name by the Land Transportation Office on __________________. Upon payment. also of legal age.000. 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. Chattel Mortgage Republic of the Philippines ) Makati City ) s. free from all liens and encumbrances that certain motor vehicle. successors and assigns. DAMI KOTSE. his heirs.S. IN WITNESS WHEREOF. of which I am the true and absolute owner by title thereto. at present in my possession at my address.s. married and resident of Makati. of legal age. this contract shall become null and void. Engine No./Color Chassis No. I have signed this instrument on 7 July 2007 at Makati City. for and in consideration of the loan of FIVE HUNDRED THOUSAND PESOS (P500. married and resident of Makati.

From MTC (as trial court) to RTC (in appellate jurisdiction) Checklist: 15 days from notice of judgment or final order Notice of Appeal Appellant’s Brief/Memorandum Appellee’s Brief/Memorandum b. in civil cases a. 7) b. Sec. 4) • Memorandum for Appellant and Appellee (Rule 40. Sec. Sec. except copy of judgment) • Appellant’s Reply Brief • Memorandum (in special cases) o Statement of the Case o Statement of the Facts o Statement of the Issues o Argument o Relief 2. APPEALS AND OTHER RESORTS TO APPELLATE COURTS IN CRIMINAL AND CIVIL PROCEDURE A. from MTC (in original jurisdiction) to RTC (in appellate jurisdiction) Checklist: • 15 days from notice of judgment or final order • Notice of Appeal (Rule 40. From RTC (as trial court) to CA Checklist: 15 days from notice of judgment or final order Notice of Appeal Appellant’s Brief/Memorandum • Appellee’s Brief/Memorandum LEGAL FORMS AND WRITING JANEIT PAJILA 94 • • • • • • • . 3) o Parties o Judgment or final order appealed from o Material dates showing timeliness of appeal • Proof of payment of appellate court docket and other lawful fees (Rule 40. Ordinary appeals 1. in criminal cases a.VII. From RTC (in original jurisdiction) to CA Checklist: • 15 days from notice of judgment or final order • Notice of Appeal • 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 • Brief for Appellee (same as Brief for Appellant.

From RTC (as trial court) to SC Checklist: 15 days from notice of judgment or final order Notice of Appeal Appellant’s Brief/Memorandum Appellee’s Brief/Memorandum LEGAL FORMS AND WRITING JANEIT PAJILA 95 .• • • • c.

From RTC (as appellate court) or from quasi-judicial agencies to CA Checklist: • 15 days from notice of judgment or final order • extension of 15 days only • Full names of petitioner and respondent • Statement of Material Dates • Statement of Material Averments • Statement of Issues. From RTC (on pure questions of law) or CA (in appellate jurisdiction) to SC Checklist: • 15 days from notice of judgment or final order • extension of 30 days • Names of petitioner and respondent (without impleading the lower court/judge/justice) • Statement of Material Dates • Material Allegations.B. Reasons or Arguments for allowance of petition • 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 • Proof of Service and Explanation for Service by Registered Mail (if applicable) LEGAL FORMS AND WRITING JANEIT PAJILA 96 . Petitions for Review 1. 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 • Proof of Service and Explanation for Service by Registered Mail (if applicable) 2.

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