Republic of the Philippines

[Region]
[COURT]
[City], [Branch No.]
[NAME]__________,
Plaintiff,
Criminal/

______

Civil

Case

No.

- versus [NAME]__________,
Defendant/Accused.
x ----------------------------------- x

For: ___________________

MOTION FOR RECONSIDERATION

PLAINTIFF/DEFENDANT/ACCUSED, through counsel, respectfully aver that
Plaintiff/Defendant/Accused received their copy of the Decision promulgated
by this Honorable Court on [STATE DATE OF RECEIPT] ________ through [STATE
MANNER OF SERVICE OF DECISION] ____________ on [STATE DATE WHEN DECISION
SENT], which reads
WHEREFORE, [STATE DISPOSITIVE PORTION OF THE DECISION SUBJECT OF
THE
MOTION]
__________________________________________________________________.
[IF FILED AFTER THE 15th DAY ALLOWED FOR FILING THE MOTION, STATE
REASON FOR LATE FILING] __________________________________________________________.
Availing of his/her rights under Section 1, Rule 52/Rule 122 of the Rules of
Court, plaintiff/defendant move for the reconsideration of the Decision promulgated
on [STATE DATE OF PROMULGATION] ________________________ based on the following:
1. [STATE GROUNDS FOR SEEKING RECONSIDERATION, i.e. for civil cases,
damages awarded are excessive, evidence is insufficient to justify the
decision or final order, or that the decision or final order is contrary to law;
for criminal cases, errors of law or fact in the judgment, which requires no
further
proceedings.]
___________________________________________________________________________
_______________________.
2. [STATE
GROUNDS
FOR
SEEKING
RECONSIDERATION]
___________________________________________________________________________
_______________________.
[DISCUSS THE GROUNDS STATED ABOVE WITH RELEVANT PROVISIONS OF LAW
AND THE RELEVANT FACTS TO SUPPORT THE REQUEST FOR RECONSIDERATION]
________________________________________________________________________.
I.

[GROUND NUMBER ONE] __________________________________________.

[INSERT
RELEVANT
DISCUSSION
FOR
FIRST
GROUND]
______________________________________________________________________________________
________________.
II.

[GROUND NUMBER TWO] ___________________________________________.

[INSERT
RELEVANT
DISCUSSION
FOR
FIRST
GROUND]
______________________________________________________________________________________
________________.
PRAYER
WHEREFORE, Plaintiff/Defendant/Accused respectfully prays for the
reconsideration of
the Honorable Courts [STATE DATE OF DECISION TO BE
RECONSIDERED] _________________ Decision/Final Order by [STATE HOW THE COURT
SHOULD
RULE
UPON
ITS
RECONSIDERATION
OF
THE
DECISION]
__________________________________________.

Other reliefs as are just and equitable are likewise prayed for.
Respectfully submitted.
[CITY] ___________; [DATE] _________________________.
[SIGNATURE]
[NAME OF COUNSEL] ___________
Counsel for Plaintiff/Defendant/Accused
[ADDRESS] ______________
IBP Lifetime No. ____________; [CITY] _____________
PTR No. _______________; [DATE], [CITY]
Roll of Attorney No. _______________________
MCLE Compliance No. ____________________

REQUEST FOR & NOTICE OF HEARING

THE BRANCH CLERK OF COURT
[COURT] ____________
[BRANCH] ____________, [CITY] __________________
Please submit the foregoing Motion to the Court for its consideration and
approval immediately upon receipt hereof and kindly include the same in the courts
calendar for hearing on Friday, [DATE] at [TIME] in the [MORNING/AFTERNOON].
[NAME] _____________________
[ADDRESS] _____________________________
Please take notice that counsel has requested to be heard on Friday, [DATE] at
[TIME] in the [MORNING/AFTERNOON].
[SIGNATURE]
[NAME] _________
Counsel for Plaintiff/Defendant/Accused
[ADDRESS] ___________________
IBP Lifetime No. ____________; [CITY] _____________
PTR No. _______________; [DATE], [CITY]
Roll of Attorney No. _______________________
MCLE Compliance No. ____________________

Copy furnished through personal service:

[NAME OF COUNSEL] __________________
Counsel for the Plaintiff/Defendant/Accused
[FIRM NAME] _______________
[ADDRESS] ________________
[USE THE FOLLOWING IF SERVICE IS NOT MADE PERSONALLY]
Copy furnished through registered mail:
[NAME OF COUNSEL] __________________
Counsel for the Plaintiff/Defendant/Accused
[FIRM NAME] _______________
[ADDRESS] ________________
Registry Receipt No. ________
Post Office ________________
Date _____________________
EXPLANATION
The foregoing [DESIGNATION OF PLEADING, MOTION, ETC] _______________and
its attachment were served on [NAME OF COUNSEL] ________________ by registered
mail instead of personal service as counsel for petitioner [STATE REASON]
___________________.
[SIGNATURE]
[NAME] _________________

Republic of the Philippines

City of _______________

)
) s.s.
AFFIDAVIT

I, [NAME] ____________ , a messenger of [NAME OF COUNSEL FOR

PLAINTIFF/DEFENDANT/ACCUSED] ______________, with office address at [ADDRESS]
__________________, after being duly sworn, deposes and states:
That on [DATE] ______________________, I served a copy of the following
pleadings/papers by registered mail in accordance with Section 10, Rule 13 of the
Rules of Court:
Nature of Pleading/Paper
[STATE PLEADING/PAPER SENT]
________________________
in Case No. [CASE NUMBER] _________________ entitled [TITLE OF CASE]
____________________ by depositing a copy in the post office in a sealed envelope,
plainly addressed to [NAME OF PARTY/ATTORNEY] _______________ at _______________
with postage fully paid, as evidenced by Registry Receipt No. _____________________
attached and with instructions to the post master to return the mail to sender after
ten (10) days if undelivered.
TO THE TRUTH OF THE FOREGOING, I have signed this Affidavit on [DATE]
________________, in the City of [CITY] _____________, Philippines.
[SIGNATURE]
[NAME] __________
Affiant
SUBSCRIBED AND SWORN TO before me in the City of _______________ on this
day of [MONTH AND YEAR]_________________, affiant exhibiting before me his
Government Issued ID no. _______________ issued on [DATE}__________________ at
[PLACE OF ISSUANCE]_____________________.
[SIGNATURE]
[NAME]_______
Notary Public
Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________
Doc. No.
Page No.
Book No.
Series of [YEAR] ___________.