REPUBLIC OF THE PHILIPPINES

[Court/Department/Commission/Board]
MANILA

[Names of Parties],

Petitioner-Appellant, d

G.R. No. XXXXX

-versus- For:
[or In re: XXXXX]

[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, Petitioner-Appellant

respectfully prays that this Honorable Court:

(a) xxxx
(b) xxxx
(c) xxxx
d
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

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING

I, Petitioner-Appellant, of legal age, do hereby state that: I caused this

Memorandum of Appeal to be prepared; I have read its contents and affirm that
they are true and correct to the best of my own personal knowledge; 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, should I learn of such
a case, I shall notify the court within five (5) days from my notice.

IN WITNESS WHEREOF, I have signed this instrument on [DATE] _____________.

[Signature]
[Name] _________________
 SUBSCRIBED AND SWORN TO before me in the City of _______________
on this _______ day of [Month], 20____, affiant exhibiting before me his
Government Issued ID No. _______________ issued on [Date]__________________ at
[Place of Issuance]_____________________.

[Signature]
[Name] _________________
Notary Public
Until [Date]__________________
PTR No. [Number] ____________
Issued at [Place]______________
On [Date] ___________________

Doc. No.
Page No.
Book No.
Series of 20 _____.

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 party’s or counsel’s 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

[USE THE FOLLOWING IF SERVICE IS NOT MADE PERSONALLY]

Copy furnished through registered mail:

[Name of Counsel] __________________

Counsel for the Respondent/Petitioner
[Firm Name] _______________
[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.

I, [Name] _____ , a messenger of [Name of Counsel], with office address at

[Address] __________________, after being duly sworn, deposes and states:
 That on [Date] ______________________, 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
[STATE PLEADING/PAPER SENT]
________________________

in Case No. [CASE NUMBER] _________________ entitled [TITLE OF CASE]

____________________ by depositing a copy in the post office in a sealed envelope,
plainly addressed to [NAME OF PARTY/ATTORNEY] _______________ at
_______________ with postage fully paid, as evidenced by Registry Receipt No.
_____________________ attached and with instructions to the post master to
return the mail to sender after ten (10) days if undelivered.

TO THE TRUTH OF THE FOREGOING, I have signed this Affidavit on

[DATE] ________________, in the City of [CITY] _____________, Philippines.

[Signature]
[Name] _________________
Affiant