Professional Documents
Culture Documents
[Court/Department/Commission/Board]
MANILA
[Names of Parties],
Petitioner-Appellant,
G.R. No. XXXXX
For:
[or In re: XXXXX]
-versus-
[Names of Parties],
Respondent-Appellee,
MEMORANDUM OF APPEAL
PETITIONER, by counsel, and in compliance with the resolution dated
___ [Date] ____ to file the respective memoranda of the parties, to this
Honorable Court, most respectfully submits this Memorandum for
Petitioners.
STATEMENT OF THE CASE
Shall contain a clear and concise statement of the nature of the action, a
summary of the proceedings, the challenged decision, order or resolution,
the nature of the judgment and any other matters necessary to an
understanding of the nature of the controversy.
STATEMENT OF THE FACTS
Shall contain a clear and concise statement in a narrative form of the facts
established.
STATEMENT OF THE ISSUES
Shall contain a clear and concise statement of the issues of fact and/or
law to be submitted for resolution
ARGUMENT
Shall contain a clear and concise presentation of the arguments in support
of each issue submitted, with citation of proper authorities.
RELIEF
Shall contain a specification of the order or judgment which the appellant seeks.
WHEREFORE,
the
premises
considered,
respectfully prays that this Honorable Court:
Petitioner-Appellant
(a) xxxx
(b) xxxx
(c) xxxx
In the alternative, Petitioner-Appellant respectfully pray that this
[Honorable Court]:
(d) xxxx
(e) xxxx
Other just and equitable relief are likewise prayed for.
____[Place]__ City for Manila. [Date]
Counsel for Petitioner-Appellant
[Attorney]
Roll No.
PTR No. XXX / Date/ Place
IBP No. XXX / Date/ Place
MCLE Compliance No. XXX/ Date
PROOF OF SERVICE
[USE THE FOLLOWING IF SERVICE IS MADE PERSONALLY]
Copy furnished through personal service:
[Name of Counsel] __________________
Counsel for the Petitioner/Respondent
[Firm Name] _______________
[Address] ________________
AFFIDAVIT
Republic of the Philippines
)
City of _______________
) s.s.
I, [Name] _____ , of legal age and having been duly sworn, depose and
state that:
I am the messenger of [Name of Counsel or Law Firm] with office
address at [Address] __________________, counsel on record for __________ in the
case entitled _____ [Case Title] ___, Civil Case No ________, G.R. No. ______, and
as such messenger, I served upon the counsel of adverse party and other
parties, the petition (or motion or other pleading) filed in said case as follows:
___[Name of Counsel or Law Firm]__, counsel of record for __
[Respondent] ___, by personal service by delivering personally copy of said the
petition (or motion or other pleading) upon said lawyer, who acknowledged
receipt thereof [or who acknowledged the same though his receiving secretary]
as shown by his signature or initials on said pleading, this __ [Date]__, 20___.
Note: if no person is found in his office, or if his office is not known, or he
has no office, then service is made by leaving a copy, between the hours of eight
in the morning and six in the evening, at the partys or counsels residence, if
known, with a person of sufficient age and discretion then residing therein.
TO THE TRUTH OF THE FOREGOING, I have signed this Affidavit on
[DATE] ________________, in the City of [CITY] _____________, Philippines.
[Signature]
[Name] _________________
Affiant
[Address] ________________
Registry Receipt No. ________
Post Office ________________
Date _____________________
EXPLANATION
The foregoing Memorandum of Appeal and its attachment were served on
[Name of Counsel] ________________ by registered mail instead of personal
service as counsel for Respondent for the reason that [state reason]
___________________.
[Signature]
[Name] _________________
AFFIDAVIT
Republic of the Philippines
)
City of _______________
) s.s.
[Signature]
[Name] _________________
Affiant