Republic of the Philippines

National Capital Judicial Region

MUNICIPAL TRIAL COURT
Branch 56, Makati

LYANNA STARK,
Plaintiff, Civil Case No. 16-0202
For: DAMAGES FOR BREACH
- versus - OF PROMISE TO MARRY

ROBERT BARATHEON,
Defendant.
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NOTICE OF APPEAL

PLAINTIFF LYANNA STARK, by counsel, respectfully appeal to the

Regional Trial Court the Decision of this Honorable Court dated 14 February
2016, a copy of which he received on 19 February 2016, for being contrary to
law and the evidence presented.

Makati City; 20 February 2016.

ATTY. RHAEGAR TARGARYEN

Counsel for the Plaintiff
Targaryen, Dayne, Selmy & Associates
No. 12, Dragonstone Street
Prince Village, Quezon City

Copy furnished:

Atty. Jon Arryn

Counsel for the Defendant
 Republic of the Philippines
National Capital Judicial Region
REGIONAL TRIAL COURT
Makati City, Branch 12

OFFICIAL RECEIPT

Official Receipt No. 0001

Date: 20 February 2016

Paid the appellate docket fees amounting to Php 10,345.00.

(Sgd.)
Arthur Dayne
Cashier
 Republic of the Philippines
National Capital Judicial Region
MUNICIPAL TRIAL COURT
Branch 56, Makati

LYANNA STARK,
Appellant,
Civil Case No. 16-0202
For: DAMAGES FOR
- versus -
BREACH OF PROMISE
TO MARRY
ROBERT BARATHEON,

Appellee.
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MEMORANDUM FOR APPELLANT

APPELLANT LYANNA STARK, assisted by counsel, unto the

Honorable Court, hereby submits her Memorandum of Appeal seeking the
reinvestigation and/or retrial of her case and in support hereof, alleges that:

TIMELINESS

Appellant received a copy of the Honorable Court’s decision dated 14

February 2016 on 19 February 2016, 5 days after the promulgation of said
decision. Hence, appellant filed his appeal on 20 February 2016, well within the
period required to file a notice of appeal.

THE FACTS

1. Appellant is a Filipino, of legal age, and resident of Makati City;

appellee, Robert Baratheon, is also a Filipino, of legal age, and resident of
Cagayan de Oro City, where he may be served with summons and other
processes.

2. Both the appellant and the appellee decided to arrange a marriage

between the appellant and the appellee set 4 September 2015 as their wedding
day. However, two (2) days before the wedding (2 September 2015), the
appellee left a note for the appellant stating that they would have to postpone the
wedding.

3. On 3 September 2015, the appellee, however, sent a telegram

apologizing and saying that nothing has changed. Despite this, on the wedding
day itself, appellee did not appear for the wedding nor was heard from again.
 4. Preparations for the ceremony were made by both the appellant and
appellee. This is in exchange for the appellant’s support in appellee’s military
campaign against Tywin Lannister.

5. Invitations were printed and distributed to relatives, friends, and

acquaintances of both the appellant and the appellee. The appellant’s trousseau,
party dresses, and other apparel for the occasion were purchased. Dresses for the
maid of honor and the flower girls were prepared. A matrimonial bed, with
accessories, was bought. Bridal showers were given and gifts were received.

6. By reason of appellee’s unreasonable failure to fulfill his promise

to marry the her, appellant was forced to engage the services of counsel to
vindicate her rights thereby committing to pay legal expenses amounting to Two
Thousand Five Hundred Pesos (P2,500.00).

7. The Honorable Judge Aerys Targaryen, issued an order of final

judgment in favor of the appellee ruling that there was no breach of promise to
marry on the part of the appellee and as such he was not liable to pay any
damages whatsoever.

8. Hence, this Memorandum on Appeal.

GROUNDS

I.
THERE IS NEW EVIDENCE TO WARRANT A REVIEW OR
REHEARING OF THE CASE

DISCUSSION

Appellant respectfully submits that there is new material evidence to

warrant a review and/or rehearing of the instant case.

1. It was found that there already exists an application for a license to

contract marriage on 23 August 2015, which was subsequently issued. The
preparations for the wedding ceremony were commenced thereafter.

2. The said application and issuance of a license to contract marriage

is vital in proving that indeed there was a promise to marry on the part of the
appellee,

3. The marriage license is sufficient evidence to prove that indeed

both the appellant and appellee intended to push through with the marriage and
the marriage ceremonies appurtenant thereto without a shed of a doubt since a
marriage license is only issued upon attendance of required pre-wedding
seminars and counseling.
 4. It is then safe to assume that both the appellant and the appellee
attended the required pre-wedding seminars and counseling in its entirety for
them to acquire the marriage license.

5. This just furthers the argument that the appellee expressed his
intent to marry the appellant and thus his inability to do so when he abandoned
the ceremonies at the last minute constitutes a breach of promise to marry.

PRAYER

WHEREFORE, in view of the foregoing, it is respectfully prayed of this

Honorable Court to grant a review or rehearing of the case, and to declare its
decision against the appellant as VOID.

Other just and equitable reliefs are also prayed for.

Makati City; 21 February 2016.

(SGD.)
ATTY. RHAEGAR TARGARYEN
Counsel for the Plaintiff
Targaryen, Dayne, Selmy & Associates
No. 12, Dragonstone Street
Prince Village, Quezon City

Copy furnished:

Atty. Jon Arryn

Counsel for the Defendant