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Republic of the Philippines

SUPREME COURT
Manila

________ DIVISION

xxxxxxxxxxxxxxx, G.R. NO. _______


Petitioner, [Consolidated Cases]

- versus–

Xxxxxxxxxxxxxxx
Respondent.
x------------------------x

MOTION
FOR EARLY RESOLUTION
COMES NOW petitioner ABC, by the undersigned counsel, to this
most Honorable Court, respectfully aver:

1. On _____________, petitioner filed before this most Honorable Court


a Petition for Review on Certiorari under Rule 45 of the Rules of Court;
On September 8, 2011, petitioner, through herein (new) counsel of
record filed a Supplemental Petition for Review by the authority of
Section 6, Rule 10, Rules of Court;

2. Since then, appropriate communications coupled with progress


monitoring of the case were constantly made by petitioner;
Significantly, new or intervening developments have had transpired
concerning the state of human affairs of the parties, the condition of
the realty itself subject of (aborted) construction, their investment plans
and practical intentions over the same and related incidental matters
that could possibly affect the pro and con outcome of the case pending
resolution of the most Honorable Supreme Court – with utmost
courtesy;
3. The passage of time has rendered the founding members1 of petitioner
Colorite wary and sickly, burdened with hypertension, recurring flu and
almost always experiencing emotional distress and body malaise;

4. Nonetheless, with patience and perseverance, petitioner will always


submit and be amenable to the processes, directives, and erudite
dispositions of the most revered members of the Honorable Court;
petitioner is also aware that case law dispensation by the most
Honorable Court will generate ‘immutable’ and in memoria effects to
litigants, guidance to the bench and the general welfare of the public –
all in maintaining democratic gains of the State’s institutions and
preserving societal norms in the community;

5. It is for the foregoing reasons that the petitioner begs the indulgence
of the most Honorable Court’s prompt resolution of the case to the end
that justice be served anchored on its own merits, after the final
determination of the core issues revolving around the contractual rights
and obligations of the herein parties.

PRAYER

WHEREFORE, it is most respectfully prayed to the most Honorable


Supreme Court that the Petition for Review (and supplement thereto) under
Rule 45 be given prompt resolution/action within reasonable time pursuant
to constitutional mandate of affording speedy disposition of cases, within the
realm of serving the higher interest of substantial justice to all concerned.

Such other relief and remedies just and equitable are likewise prayed
for.

Respectfully submitted. City of Manila, December___, 2014.

1
Collectively as incorporators, contributors and/or stakeholders led by Sister Conchita Mercader who
continue to support the socio-spiritual aims of Holy Buddhist Temple {in dynamic partnership with Colorite
Marketing Corporation}; Please refer to handwritten letter of Sister Mercader with attached pictures
(submitted on October 27, 2014 to the SC through Atty. Lucita A. Soriano) of outreach programs being
conducted for the past decades by Holy Buddhist Temple Foundation.
EXPLANATION
(Pursuant to Section 11, Rule 13
of the 1997 Rules of Civil Procedure)

Due to distance of below-indicated addressees, and lack of personnel


in the law office of undersigned counsel, personal service was not resorted
to, hence, this Motion for Early Resolution is being filed and served by
registered mail with return card.

Copy furnished:

Xxxxxxx
(Counsel for the Respondent cccccccc)
Address