Republic of the Philippines

COURT OF APPEALS
Manila

______________,
Petitioner,

- versus - G.R. No. _______________

HON. ___________, Executive Judge,

Regional Trial Court ________,
____________________________,
Respondents,
X----------------------------X

PETITION FOR CERTIORARI

With PRAYER FOR A WRIT OF
PRELIMINARY PROHIBITORY
INJUNCTION
COMES NOW, Petitioner _____________, by undersigned
counsel, unto the Honorable Court, respectfully states: THAT -

PREFATORY

I. NATURE AND PURPOSE OF THE PETITION

1. This is a Petition for Certiorari under Rule 65 of the 1997

Rules of Civil Procedure seeking to set aside the _____________.

II. TIMELINESS OF THE PETITION

III. THE PARTIES

 IV. STATEMENTS OF FACTS
AND OF THE CASE

V. GROUNDS FOR THE ALLOWANCE

OF THE PETITION

2. With due respect, this Petition for Review on Certiorari is

anchored on the following grounds:

A.

THE PUBLIC RESPONDENT HON. __________

GROSSLY ACTED WITH GRAVE ABUSE OF
DISCRETION AMOUNTING TO LACK
AND/OR EXCESS OF JURISDICTION
WHEN______________________________.

B.

THE PUBLIC RESPONDENT HON. __________

GROSSLY ACTED WITH GRAVE ABUSE OF
DISCRETION AMOUNTING TO LACK
AND/OR EXCESS OF JURISDICTION
WHEN______________________________.

VI. ARGUMENTS AND DISCUSSIONS

A. THE PUBLIC RESPONDENT HON.

______________________________.

1.

B. THE PUBLIC RESPONDENT HON.

______________________________.

2.

2
 VII. PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court that the assailed ______________ be
reversed and set-aside, and that a decision be rendered granting the
instant petition and for the issuance of a writ of preliminary injunction
to _________________.

Petitioner prays for such other reliefs and remedies that the
Honorable Court may deem just and equitable in the premises.

Pasig City for City of Manila, August 30, 2017.

Pursuant to Sec. 11, Rule 13 of the 1997 Revised Rules of Court,

a copy of the Petition for Certiorari was sent by registered mail with
return card due to distance and inability of the messengerial personnel
to effect personal service.

<ATTACH THE VERIFICATION & CERTIFICATE OF NON

FORUM SHOPPING>

3
Republic of the Philippines)
Manila ) S.S.

AFFIDAVIT OF MAILING

I, RITOBERT P. TANGUILAN, of legal age, Filipino after being

duly sworn in accordance with law, hereby depose and state that:

1. I am the liaison officer of THE LAW FIRM OF GARAY PICHAY

MONTUBIG SANIDAD & GISON, counsel for petitioner in
the above-entitled case;

2. I furnished a copy of this Petition for Review on Certiorari by

registered mail with return card to:

ATTY. REGIDOR C. CARINGAL

RUGA DELFIN & CARINGAL LAW OFFICES
Unit 1641 & 1642 City and Land Mega Plaza Condominium Building
ADB Avenue corner Garnet Road
1605 Ortigas Center, Pasig City

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo Street, Legaspi Village
1229 Makati City

HON. PRESIDING JUDGE

REGIONAL TRIAL COURT
Branch 161, Pasig City
Hall of Justice
1600 Pasig City

Further Affiant Sayeth Naught.

RITOBERT P. TANGUILAN
Affiant

SUBSCRIBED AND SWORN to before me this _____ day of August, 2017,

affiant exhibiting to me his government issued I.D., Unified Multi-Purpose ID CRN-
0111-1379323-2.

Doc No.
Page No. Notary Public
Book No.
Series of 2017