Counsel for the petitioners submits a soft copy of a compliance document as required by the Supreme Court. The compliance explains that a soft copy was not initially filed due to a typhoon that required hastily filing the hard copy in person. It is requested that the compliance and submission be admitted in the interest of justice. Proof of service is also provided, having been served by registered mail to the necessary parties due to constraints of distance and time that made personal service and filing impracticable.
Counsel for the petitioners submits a soft copy of a compliance document as required by the Supreme Court. The compliance explains that a soft copy was not initially filed due to a typhoon that required hastily filing the hard copy in person. It is requested that the compliance and submission be admitted in the interest of justice. Proof of service is also provided, having been served by registered mail to the necessary parties due to constraints of distance and time that made personal service and filing impracticable.
Counsel for the petitioners submits a soft copy of a compliance document as required by the Supreme Court. The compliance explains that a soft copy was not initially filed due to a typhoon that required hastily filing the hard copy in person. It is requested that the compliance and submission be admitted in the interest of justice. Proof of service is also provided, having been served by registered mail to the necessary parties due to constraints of distance and time that made personal service and filing impracticable.
PETITIONERS, through counsel, to the Honorable Supreme Court, respectfully submit the following and respectfully allege:
1. That the undersigned counsel received a NOTICE on September 19, 2014 resolving and require counsel for Petitioners, among others, the following, to wit:
xxxx (3) REQUIRE Atty. Modesto T. Andong, counsel for petitioners, to SUBMIT to the Court soft copy of said compliance in portable document format pursuant to A.M. No. 11-94-SC (Efficient Use of Paper Rule, effective October 2, 2013) within five (5) days from notice; and
2. That the undersigned counsel filed the Compliance (complying the Notice dated June 4, 2014), on July 21, 2014, however, SOFT COPY of said Compliance was not filed together with the hard copy due to the fact that during that 2
time a strong typhoon hit most part of the Northern Luzon and undersigned counsel have to rushed the making of the said Compliance and have to personally file the same with the Honorable Court, due to such circumstances, undersigned counsel inadvertently forgot to prepare the SOFT COPY, hence, this Compliance;
WHEREFORE, petitioners respectfully pray of the Honorable Tribunal to admit the compliance and submission, in the interest of justice and equity.
They further pray for such other remedies just and equitable in the premises.
Baguio City for Manila, September 19, 2014.
MODESTO T. ANDONG Counsel for the Petitioners Rm. 21, 2 nd floor, Old Market Bldg., Magsaysay Ave., Baguio City ROLL No. 31289, 5.15.81, Manila PTR No. 1575953/01-03-14/Baguio City IBP No. 937789/12-12-13/Baguio-Benguet Chapter MCLE COMPLIANCE No. IV-0000175/August 4, 2010
NOTICE
ATTY. WILFREDO V. LAPITAN DIVISION CLERK OF COURT THIRD DIVISION SUPREME COURT, MANILA
DEAR SIR:
GREETINGS!
Please submit the foregoing Compliance and Submission for the kind consideration and approval of the Honorable Division.
Thank you.
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MODESTO T. ANDONG Counsel for the Petitioners
REPUBLIC OF THE PHILIPPINES) DONE: In the City of Baguio ) s.s.
PROOF OF SERVICE AND FILING
I, MODESTO T. ANDONG, as counsel for petitioners in the above-entitled case and with office address at Rm. 13-B 2 nd floor, Old Market Bldg., Magsaysay Avenue, Baguio City, under an oath, do hereby depose and state that:
PROOF OF SERVICE. On September 19, 2014 I caused to served by registered mail a copy of the foregoing Compliance to Atty. Matthew Dati, counsel for the respondent, with office address at ALS Building, Km. 6, La Trinidad, Benguet Province, under Registry Receipt No. _________, which is hereto attached to the original copy.
Also on September 19, 2014, I caused to serve by registered mail a copy of the foregoing Compliance on the Honorable Court of Appeals under Registry Receipt No. _________, which is hereto attached to the original copy which is hereto attached to the original copy.
Likewise on September 19, 2014, I caused to serve by registered mail a copy of the foregoing Compliance on the Honorable National Commission on Indigenous Peoples, 2 nd
Floor Dela Merced Bldg., Quezon Ave., cor. West Ave., Quezon City under Registry Receipt No. ______________, which is hereto attached to the original copy.
PROOF OF FILING. On September 19, 2014, I filed by registered mail the foregoing Compliance in five (5) copies under Registry Receipts Number ____________, with the instructions to the postmaster to return the mail matter to the sender after ten (10) days if not delivered, in accordance with Sec. 12, Rule 13, of the 1997 Rules of Civil Procedure.
EXPLANATION. The filing and service of the foregoing Compliance to the CA, NCIP and Atty. Matthew Dati by registered mail were resorted to by the petitioners because of constraints of distance and time, rendering of personal service and personal filing impracticable.
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IN WITNESS WHEREOF, I have hereunto set my hand this 19 th day of September, 2014 at Baguio City, Philippines.
MODESTO T. ANDONG Affiant
SUBSCRIBED AND SWORN to before me this 19 th day of September, 2014 at Baguio City, Philippines, affiant exhibiting to me his GSIS identification card bearing serial number 4404- 5277-2963-9506 issued on March 3, 2006 by the GSIS Baguio City Branch Office.
Doc. No. _____; Page No. _____; Book No. ____; Series of 2014.