Republic of the Philippines

Regional Trial Court

Branch 9, Tacloban City

A and B, Civil case:

Plaintiff

-versus-

C,

Respondent

STATEMENT OF THE CASE

ISSUES

Whether or not the adopters can rescind the decree of adoption?

Whether or not C can refuse to use the family name of his adopters?

ARGUMENTS AND DISCUSSIONS

PRAYER

All other just and equitable reliefs are also prayed for.
RESPECTFULLY SUBMITTED.

Tacloban City; 24 August 2013.

Atty. _________________________
Counsel for the Accused Appellant
LAW OFFICE
Filipinas St. corner J. Pacheco St. Brgy. Naga-Naga Palo, Leyte
Attys. Roll No. 55555/May 10, 2007
PTR No. 1111111 issued on January 4, 2012 at Tacloban City
IBP OR No. 777777 issued on January 26, 2013 at Tacloban City
MCLE COMPLIANCE NUMBER III-0006695/ November 10, 2012
Contact No. ________________
Email Add: __________@yahoo.com

VERIFICATION

I, ATTY._______________________, of legal age, and a resident of

_________________, after having been duly sworn to in accordance with
law hereby state that:
 1. By way of a Special Power of Attorney, I have been duly authorized
by the accused-appellants to, among other acts, prepare, sign and
submit this Memorandum;

2. I caused the preparation of this same pleading in coordination,

consultation, and conformity with the accused-appellants, the real
party in interest; and

3. I and the accused-appellants have read the contents thereof and the
facts stated therein are true and correct, of our personal knowledge
and/or on the basis of copies of authentic documents and records in
my possession.

IN WITNESS WHEREOF, I have hereunto affixed my signature, this

_______ day of ________, 2014 in Tacloban City, Philippines.

_____________________
Affiant
Competent Proof of Identity: IBP ID NO: ___________

SUBSCRIBED and SWORN to before me this ______ day of

_______ 2014, in Tacloban City, Republic of the Philippines.

Doc No.
Page No.
Book No. III
Series of 2012

Copy Furnished

Office of the Solicitor General

134 Amorsolo Street, Legazpi Village
Makati City, Philippines
Mail Registry Receipt No.: ______________ Dated: _______________

EXPLANATION ON THE MODE OF SERVICE

Service of a copy of this pleading upon adverse counsel was done by

registered mail was made for reason of lack of personnel to effect personal
service and the distance between law offices of both counsels.

ATTY. _________________________