REPUBLIC OF THE PHILIPPINES COURT OF APPEALS MANILA GWENDOLYN F. GARCIA, Petitioner, - versus CA-G.R. No. 127933 (O.

P CASE NO. 10-K-504) THE COURT OF APPEALS, HON. GREGORIO G. SANCHEZ, JR., VICE GOVERNOR OF THE PROVINCE OF CEBU, HON. EXECUTIVE SECRETARY PAQUITO M. OCHOA, JR., THE OFFICE OF THE PRESIDENT, HON. SECRETARY MAR A. ROXAS, and THE DEPARTMENT OF INTERIOR AND LOCAL GOVERNMENT, Respondents. x ----------------------------------------------------- x VERY URGENT MOTION REITERATING THE ISSUANCE OF A TEMPORARY RESTRAINING ORDER AND/OR STATUS QUO ANTE ORDER Petitioner GWENDOLYN F. GARCIA, Governor of the Province of Cebu (Governor Garcia), by counsel, respectfully alleges: 1. On 10 January 2013, oral arguments were heard before Justices of the 12th Division of the Court of Appeals (the Hearing) to present the factual and legal arguments of Governor Garcias application for a Temporary Restraining Order (TRO) and/or Status Quo Ante Order. 2. During the Hearing, Governor Garcia sought to establish the urgency and the grave and irreparable injury that she suffered and continues to suffer, which entitles her to the issuance of a TRO and/or status quo ante order, by this Honorable Court. 3. After the Hearing, the incident was submitted for resolution by the Honorable Court.
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4. Thirty-one days had passed since the illegal suspension of Governor Garcia. Several damaging and alarming events have transpired causing grave and irreparable injury not only to Governor Garcia and her family, but also to the people and the province of Cebu. 5. Over a week had passed since the Hearing. However, despite the urgency posed by the circumstances, no action has yet been taken. 6. Unless a TRO and/or status quo ante order is issued, Governor Garcia and the Province of Cebu will continue to suffer grave and irreparable damage and injury. 7. Petitioner respectfully repleads all the allegations in her Petition in support of the issuance of the Temporary Restraining Order, Status Quo Ante Order and Preliminary Injunction. PRAYER WHEREFORE, premises considered, Governor Gwendolyn F. Garcia respectfully reiterates her prayer that this Honorable Court: (a) issue a Temporary Restraining Order / Status Quo Ante Order, upon the filing of the Petition, and after hearing, a Writ of Preliminary Injunction enjoining the Public Respondents from implementing the invalid Suspension Order, and thus allowing Governor Garcia to continue holding Office as Governor of the Province of Cebu, and preserving the status quo ante litem motam; (b) after hearing, make the Preliminary Injunction permanent; Makati City for Manila, 18 January 2013.