Republic of the Philippines

SUPREME COURT

Manila

MOTION FOR ALLOWANCE TO APPEAR AS AMICUS CURIAE

Movant, by himself, by special appearance to this Honorable Court, most respectfully states:

That herein Movant was an elected Senator and served during the year 1988-1995.

Movant was the principal author of Batas Pambansa Blg. 885 or “An Act Creating a New Province in the Island of Negros to be known as the Province of Negros del Norte.” Movant has extensively and exhaustively crafted the said bill during the senate deliberations for the same during the years he served as a Senator.

That the present case sprung from the construction of Sec 5(3) therein, which the committee deliberations have not accompanied an explanatory note.

That to ensure the meaningful discussion and appreciation of the issues as raised in the abovementioned case before the Honorable Court, Movant request that he be made a resource speaker to aid the Court in the case’s speedy disposition.

WHEREFORE, undersigned hereby respectfully requests that he be allowed to appear before the Honorable Court as an amicus curiae to aid the court in the speedy disposition of the present case.

City of Manila, October 19 1996.

AMBROSIO PADILLA

Movant

Notice

HONORABLE SUPREME COURT

City of Manila

Greetings:

Please submit the foregoing motion for the consideration and approval of the Honorable Court immediately upon receipt hereof.

AMBROSIO PADILLA