Republic of the Philippines

[Department of ________]
[ADMINISTRATIVE BODY]
[Address]

[NAME],
Complainant,

-versus- CASE NO. XXXX-XXX

[NAME],
Respondent.

x - - - - - - - - - - - - - - - - - - - - - - - - -x

MOTION FOR ISSUANCE OF A CEASE AND DESIST ORDER

Complainant, pro se or by counsel, and unto this Honorable Body, respectfully

states that:

STATEMENT OF FACTS

[description of material events, circumstances, the acts of respondents, and the

legal provision that serve as basis for the issuance of a cease and desist order.]

A cease and desist order is similar in nature to a status quo order

rather than a temporary restraining order or a preliminary
injunction since a status quo order does not direct the doing or
undoing of acts, unlike in the case of prohibitory or mandatory
injunctive relief. A status quo order, as the very term connotes, is
merely intended to maintain the last, actual, peaceable, and
uncontested state of things which preceded the controversy. [GMA
Network vs. NTC, G.R. No. 181789, February 3, 2016]

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that a Cease

and Desist Order be issued restraining the herein Respondents from:

(1) xxx
(2) xxx

The Complainant likewise respectfully prays that, after notice and hearing, the
foregoing Cease and Desist Order be made permanent and perpetual.
Lastly, the Complainant prays for such other reliefs as may be deemed just and
equitable under the premises.

[Place], [Date].

[signature]
[Name of Complainant]

[if represented by counsel]

by:

[Lawyer]
IBP No. XXXXX
PTR No. XXXXX
Attorney’s Roll No. XXXXX
MCLE Compliance No. XXXXX

NOTICE

Hon. ___________
[ADMINISTRATIVE BODY]
[Address]

Greetings:

I am submitting the foregoing “Motion for the Issuance of a Cease and Desist
Order”, for your kind and urgent consideration, subject to your discretion to
require the Respondent to file a Comment/Opposition thereon. The herein
Respondent is duly furnished a copy of this motion via [personal service or
registered mail].

[signature]
[Name of Complainant]

Copy furnished through personal service:

[RESPONDENT NAME]
[ADDRESS]
[USE THE FOLLOWING IF SERVICE IS NOT MADE PERSONALLY]

Copy furnished through registered mail:

[RESPONDENT NAME]
[ADDRESS]
Registry Receipt No. ________
Post Office ________________
Date _____________________

EXPLANATION

The foregoing MOTION FOR ISSUANCE OF A CEASE AND DESIST ORDER

and its attachments were served on [NAME] by registered mail instead of
personal service for the reason that [STATE REASON].

[SIGNATURE]
[NAME]

AFFIDAVIT

Republic of the Philippines )

City of _______________ ) s.s.

I, [NAME], a messenger of [NAME], with office address at [ADDRESS],

after being duly sworn, deposes and states:

That on [DATE], I served a copy of the MOTION FOR ISSUANCE OF A

CEASE AND DESIST ORDER by registered mail in accordance with Section 10,
Rule 13 of the Rules of Court 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 [PLACE], 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].

Notary Public
Until [DATE]
PTR No. [NUMBER]
Issued at [PLACE]
On [DATE]

Doc. No.
Page No.
Book No.
Series of [YEAR].