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CITY GOVERNMENT OF
TUGUEGARAO CITY and
MAYOR DELFIN TING,
Defendants.
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MOTION TO DISMISS
GROUND
Mayor Delfin T. Ting acted beyond the scope of his authority. Thus,
he must be only sued on his private capacity.
DISCUSSION
PRAYER
Such other reliefs just and equitable in the premises are prayed for.
NOEL A. MORA
Counsel for defendant Tuguegarao City
Tuguegarao City Legal Office
IBP OR NO. 946929/01-05-16
PTR OR NO. 1781116/01-05-16
MCLE Compliance No. V-0014514
Roll No. 42605
CP No. 0917-537-0555
Email: noelmora19@yahoo.com
GREETINGS:
Please take notice of the foregoing motion to dismiss for the kind
consideration of this Honorable Court.
Thank you.
NOEL A. MORA
Copy furnished:
EXPLANATION
NOEL A. MORA
PREFARATORY STATEMENT
In May, 2010, defendant Mayor Ting and plaintiff Annang met in
Tuguegarao City, and in the presence of an Engineer of the NIA, agreed
before the construction of the impounding dam will be started, a written
agreement or contract will be first be executed between them to lay down the
terms and conditions thereof but despite efforts of plaintiffs to have the
contract or agreement executed and signed, Mayor Ting failed and refused to
respond affirmatively giving a flimsy reason that he is busy.
The