Escolar Documentos
Profissional Documentos
Cultura Documentos
COURT OF APPEALS
MANILA
HALBERT UY,
Plaintiff-Appellee,
- Versus -
WESTMONT MAMBURAO
BEACH RESORT, INC., AND
ANTONIO ONG,
Defendant-Appellant.
X* * * * * * * * * *X
MOTION FOR LEAVE OF COURT
TO ADMIT PLAINTIFF-APPELLEES BRIEF
5.
In the highest and broadest interest of substantial justice,
Undersigned Counsel sincerely express his profuse apologies and
humbly beseech and seeks leave that the Plaintifff-Appellees Brief
attached herewith, be Admitted to form part of the case records and
be considered in the Decision of Disposition of the instant case;
6.
The emerging trend in our jurisprudence is to afford every
party- litigant the amplest opportunity for the proper and just
determination of his cause free from the constraints of technicalities.
While it is desirable that the Rules of Court be faithfully and even
meticulously observed, court should not be so strict about procedural
lapses that do not really impair the administration of justice. (PACIFIC
UNION INSURANCE COMPANY vs. CONCEPTS & SYSTEMS
DEVELOPMENT INCORPORATED and COURT OF APPEALS,
FIFTEENTH DIVISION, G.R.No. 183528, February 23, 2011).
P R A Y E R
WHEREFORE, premises considered, it is most respectfully
prayed and humbly beseeched of this Honorable Court that this
Motion be Granted and that the Plaintifff-Appellees Brief attached
herewith, be Admitted to form part of the case records and be
considered in the Decision of Disposition of the instant case.
Other reliefs and remedies just and equitable under the
premises are likewise prayed for.
City of Manila, April 20, 2016.
Greetings.
3
Please take Notice that Undersigned Counsel will submit the
foregoing Motion for the kind consideration and approval of the
Honorable Court, immediately upon receipt hereof.