Appellant's Brief

Republic of the Philippines

SUPREME COURT

Manila

__________________________________,

Petitioners,

-versus-

__________________________________,

Respondent.

x - - - - - - - - - - - - - - - - - - - - - - - - -x



G.R. DOCKET NO. _____________________

FOR: __________________________________

STATEMENT OF THE CASE

(Clear and concise statement of the nature of the action)

STATEMENT OF THE FACTS

(A summary of the proceedings, the appealed rulings and orders of the court, the nature of the judgement and any other matters necessary to an understanding of the nature of the controversy, with page references to the record)

THE ISSUES/ASSIGNMENT OF ERRORS

ARGUMENT

(Under this heading, the appellant should argue on each assignment of error with page reference to the record. The authorities relied upon shall be cited by page of the report at which the case begins and the page of the report at which the citation is found.)

      1. First error;

      2. Second error;

      3. Third error.

RELIEF

(Under this heading, appellant should make specification of the order of judgment which he seeks)

(Venue, date, signature)

(Explanation)

(Affidavit of Service)

PRAYER FOR RELIEF

WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court that it REVERSE AND SET ASIDE the Decision of the Regional Trial Court of Cebu City, Branch 9, dated July 11, 2006, in Civil Case No. CEB-31568 and consequently declare that a prior authorization, in the form of a resolution, from the Sangguniang Panlalawigan of the Province of Cebu is required before herein Respondent can enter into a contract involving monetary obligations on the part of the Province.

Other relief, just and equitable, are also prayed for.

Cebu City, August 17, 2016.

By the Counsel for the Petitioners

CABRADILLA, DUCE AND PABUAYA LAW OFFICE

Room 204, CRM Building,Corner Escario and Molave Streets,

Lahug,Cebu City 6000

Telephone Number: (032) 253-1890 to 92

Fax Number: (032) 253-1893

E-mail Address: inquiry@cdplawoffice.com


ARFEL JANE C. CABRADILLA

Roll No. 44403

IBP No. 9849 (Lifetime) Cebu City

MCLE Compliance No. III-0008600

PTR No. 1161031-5-8-2016-Cebu City

Telephone No. (032) 253-1890 local 101

E-mail Address: ajccabradilla@cdplawoffice.com


Copy furnished, in accordance with

Section 11, Rule 13 of the Revised Rules of Court, by registered mail, in

view of far distance making personal service not practicable, to:

ATTY. JOHN EMMANUEL F. MADAMBA

Assistant Solicitor General

134 Amorsolo Street,

Legaspi Village, Makati City

and by personal service, to:

ATTY. MARINO E. MARTINQUILLA

Cebu Provincial Legal Officer

3rd Floor, Capitol Building,Cebu City

ATTY. CHEVIN Q. VASQUEZOIC,

Clerk of Court V

Regional Trial Court of Cebu City, Branch 9,

3/F Qimonda IT Center,

Sergio Osmeña Boulevard,

Cebu City