Republic of the Philippines

[Region]
[COURT]
[City], [Branch No.]

[NAME]__________,
Plaintiff,
Criminal/ Civil Case No. ______
- versus -

[NAME]__________, For: ___________________

Defendant/Accused.
x ----------------------------------- x

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 Court’s [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 court’s 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] ___________.