REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

10th Judicial Region
Branch __
Malaybalay City, Province of Bukidnon

KRIS AQUINO, CIVIL CASE NO:

Plaintiff, __________________

-versus-
For:
INJUNCTION WITH
KORINA SANCHEZ URGENT PRAYER FOR
Defendant. THE ISSUANCE OF A
WRIT OF PRELIMINARY
PROHIBITORY
INJUNCTION AND
TEMPRORARY
RESTRAINING ORDER
(TRO)
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MOTION TO AMEND
PETITION FOR INJUNCTION
PLAINTIFF, through counsel and before this Honorable Court most
respectfully states that:

1. On April 6, 2018, Plaintiff filed a Petition for Injunction with Urgent

Prayer for the Issuance of a Writ of Preliminary Prohibitory Injunction and
Temprorary Restraining Order (TRO) against herein Defendant;

2. To date, Defendant has not served his answer to the earlier filed
Petition;

3. In this regard, Plaintiff through undersigned counsel respectfully moves

to amend the earlier filed Petition for Injunction pursuant to Section 2, Rule
10 of the 1997 Rules of Court1;

4. The Amended Petition for Injunction with Urgent Prayer for the
Issuance of a Writ of Preliminary Prohibitory Injunction and Temprorary
Restraining Order (TRO) maintains the allegations against the same
defendant but incorporates therein additional factual allegations constitutive
of Plaintiffs’ cause of action against defendants;

1
Sec. 2. Amendments as a matter of right - A party may amend his pleading once as a matter of right at
any time before a responsive pleading is served or, in the case of a reply, at any time within ten (l0) days
after it is served.
1
5. Moreover, the Amended Petition sought to account for the Letter
Demand for the Inventory, Accounting and Partition or Settlement which
Plaintiff received thru undersigned counsel on the same day when the
Petition is filed. The said letter-demand must be considered as it necessarily
affects the property subject of the dispute in the instant Petition for
Injunction;

6. The instant petition may effectively proceed on the merits if all the
allegations set forth in Plaintiff’s proposed amended petition.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that Plaintiff’s Motion to Amend be GRANTED.

Other just and equitable reliefs applicable under the circumstances are
likewise prayed.

Most respectfully submitted.

Malaybalay City, ____ April 2018.

BOY ABUNDA
Counsel for the Accused
Don Carlos St., Malaybalay City
Landline No. 813-5446