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Appeal by petition for review within 15 days to CA

REPUBLIC OF THE PHILIPPINES


COURT OF APPEALS
Manila

REA MICHELLE IRISH PINTOR,


Petitioner,

CA-G.R. SP. No. ____

-versus-

MIKAELA AURELIO
Respondent.

x————————————————————————-x

PETITION FOR REVIEW

Petitioner, by counsel and to this Honorable


Court respectfully alleges:

NATURE OF THE PETITION

This is a Petition for Review pursuant to Rule 42


of the ROC of the decision of the Regional Trial Court
of Manila, Branch 1, entitled Rea Michelle Irish Pintor
vs. Mikaela Aurelio, Civil Case No. 00001, which
affirmed the decision of the Metropolitan Trial Court
in Civil Case No. 00001 dismissing plaintiff’s (now
petitioner’s) complaint for ejectment, upon
defendant’s (now respondent’s) motion to dismiss on
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the ground that the RTC, in the exercise of its


appellate jurisdiction, committed in its decision
errors of law and facts.

I.
THE PARTIES

1. Petitioner Rea Michelle Irish Pintor, of legal age,


single, and a resident of 1 Recto Ave., Manila while
respondent Mikaela Aurelio is of legal age, single, and
a resident of 11 Recto Ave., Manila.
II.
TIMELINESS OF PETITION

2. On March 24, 2016, petitioner received a copy of


the decision of the RTC in Civil Case No. 00001.
Certified true copy of the decision is attached hereto
as Annex “A”.

3. On April 4, 2016, or within the 15-day period from


receipt of said decision Annex “A”, petitioner filed a
motion for reconsideration of said decision. On April
9, 2016 , the trial court denied said motion for
reconsideration, copy of which was received by
petitioner on April 21, 2016. Certified true copy of the
order denying the motion for reconsideration is
attached hereto as Annex “B”.

4. The instant petition is filed within 15 days from


receipt on May 02, 2016 of the order denying the
motion for reconsideration. (Annex “A”)

III.
STATEMENT OF FACTS
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The factual background and proceedings are as


follows:
(Here make concise statement of the facts and
proceedings that took place in the MTC and RTC, until
the latter rendered its questioned decision and its
date of receipt by petitioner.)

IV.
ISSUE RAISED
The issues raised in this petition are:
(Enumerate only issues of law)

V.
ERRORS COMMITTED BY TRIAL COURT

(Enumerate the errors of facts and law)

VI.

GROUNDS OR REASON FOR ALLOWANCE OF WRIT


PRAYED FOR

(Enumerate the grounds or reasons)

VII.
DISCUSSION
(Discuss in detail each of the grounds)

VIII.
PRAYER

WHEREFORE premises considered, petitioner


respectfully prays from this Honorable Court:

1. That the Decision dated [Date of Judgement] be set


aside;
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2. That the case be remanded to the lower court for


further proceedings; and
3. That attorney’s fees and costs of suit be
shouldered by Respondent.

Other reliefs that may be just and equitable are


likewise prayed for.

City of Manila, Philippines, May 20, 2016.

ATTY. GABRIEL REYES


Counsel for Petitioner
Unit 1, X Building, Recto, Manila
IBP No. 123456; 01/10/10-Manila
PTR No. 1234567; 01/10/10- Manila
Roll No. 12345; 5/05/05
MCLE No. I-001234; 09/09/09
MCLE No. II-005678; 9/09/09

VERIFICATION AND CERTIFICATION OF NON-FORUM


SHOPPING

JURAT

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