resolution dated _____ to file the respective memoranda of the parties, to this Honorable Court, respectfully submits this Memorandum for Petitioners.
STATEMENT OF THE CASE
“Statement of the Case,” is a clear and concise statement of
the nature of the action; a summary of the proceedings; the challenged decision, resolution, or order of the court below, the nature of the judgement, and any other matters necessary to an understanding of the nature of the controversy.
STATEMENT OF THE FACTS
“Statement of the Facts,” is a clear and concise statement in
a narrative form of the established facts.
STATEMENT OF THE ISSUES
2 of 2
A “Statement of the Issues” is a clear and concise statement
of the issues submitted to the Court for resolution which should be limited to issues of law only.
ARGUMENT
The “Argument” is a clear and concise presentation of the
argument in support of each issue.
RELIEF
WHEREFORE, petitioner respectfully prays that the
questioned decision Annex “A” and the order Annex “B” be set aside and nullified, and another one rendered granting petitioner the following reliefs:
(Copy)
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