You are on page 1of 4

REPUBLIC OF THE PHILIPPINES

COURT OF APPEALS
Manila
THIRD DIVISION

CLARITA A. AGUILAR,
Petitioner,
- versus -

CA-G.R. SP. No. 120470

FIELD INVESTIGATION OFFICE (FIO)


(OFFICE OF THE OMBUDSMAN) and
THE SECRETARY OF HEALTH,
Respondents.
x---------------------------------------------------x
MOTION FOR LEAVE TO FILE COMMENT
(RE: RESPONDENT FIO OFFICE OF THE OMBUDSMAN'S
MOTION FOR RECONSIDERATION)
with
MOTION TO ADMIT ATTACHED COMMENT
PETITIONER, by undersigned counsel, and to the Honorable Court,
respectfully states:
1.

On 17 July 2012, petitioner through counsel received the

Motion for Reconsideration of the 20 June 2012 Decision of the Honorable


Court filed by respondent Field Investigation Office (FIO), Office of the
Ombudsman, dated 10 July 2012.
2.

Petitioner wishes to invite the attention of the Honorable Court

to the obvious vagueness of the relief sought for by movant-FIO in its


Motion for Reconsideration. Evident from the Prayer of the said motion,
the relief sought for by the respondent is ambiguous as to what extent or in
what sense does respondent submits the decision to be reconsidered.

3.

Accordingly, petitioner respectfully moves that her Comment

on the respondent FIO - Office of the Ombudsman's Motion for


Reconsideration of the Honorable Court's 20 June 2012 Decision, which she
is filing simultaneously herewith, be admitted so as to fully protect her
rights and interest in the instant case.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed that:
(i)

Petitioner be granted leave of court to file her Comment on

the Motion for Reconsideration filed by the FIO; and


(ii)

Accordingly, that the Comment, which Petitioner is filing

herewith, BE ADMITTED.
Other reliefs just and equitable in the premises are also prayed for.
Pasig City for Manila, 01 August 2012.

BENJAMIN C. SANTOS
& RAY MONTRI C. SANTOS
LAW OFFICE
Counsel for Petitioner
Clarita A. Aguilar
Suite 2304C, West Tower
Philippine Stock Exchange Centre
Exchange Road, Ortigas Center, Pasig City
T: (02) 696-7127 T/F: (02) 696-6982

By:

RAY MONTRI C. SANTOS


PTR No. 7577706; 01.17.12; Pasig City
IBP Life Roll No. 04981; Quezon City
Roll of Attorneys No. 38624
MCLE Compliance No. III 0020870 08.03.11

NOTICE
THE CLERK OF COURT
Court of Appeals
Manila
Greetings:
Please submit the foregoing Motion for leave to File Comment with
Motion to Admit Attached Comment for the consideration and resolution of
the Honorable Court immediately upon receipt hereof.

RAY MONTRI C. SANTOS


EXPLANATION
(Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure)
This pleading is being filed with the Honorable Court and served on
the other parties by registered mail for reasons of convenience and
expediency, personal service being impracticable due to time, distance and
personnel constraints. (Please disregard if service has in fact been effected
personally).

RAY MONTRI C. SANTOS


COPY FURNISHED:
FIELD INVESTIGATION OFFICE
Office of the Ombudsman
Agham Road, Diliman, Quezon City
SECRETARY OF THE DEPARTMENT
The Legal Department Head, Department of Health
San Lazaro Compound, Sta. Cruz, Manila
OFFICE OF THE SOLICITOR GENERAL
134 Amorsolo St., Legaspi Village
Makati City
THE MEDICAL CENTER CHIEF
National Center for Mental Health
9 de Febrero St.
Mandaluyong City

mag \ aguilar \ m-leave to file comment on mr