Republic of the Philippines
SUPREME COURT Manila ________ DIVISION DIVISION
xxxxxxxxxxxxxxx, xxxxxxxxxxx xxxx,
Petitioner,
G.R. NO. _______ [Consolidated Cases]
- v e r s u s – 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 communicatio ns 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 conditio n 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 the pro and and con outcome 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 E arly R es olution is being filed and served by registered mail with return card.
Copy furnished: Xxxxxxx (Counsel for the Respondent cccccccc) Address
