Republic of the Philippines

SUPRME COURT
MANILA

FIRST DIVISION

MOMOLAND REALTY
CORPORATION, TIMBERLAND
HOMEOWNERS, ET AL.,

Petitioners,

- versus - GR NO. 22222

EMILY BLONDE, in her

capacity as the Secretary of
the Department of
Environment and Natural
Resources, ET AL.,

Respondent,

KRIS MERTIN, GUY

BERIMEN, WILL CAMPION,
JONY BACKLAND,

Intervenors,

X-------------------------------------------------------------X

MOTION FOR INTERVENTION

COMES NOW the Intervenor, by the undersigned

counsel, and unto this Honorable Court, most respectfully
requests for leave to intervene in the above-captioned case,
for the following reasons:
1. That the Intervenors are Filipino citizens;

2. That the Intervenors are purchasers of some of

the subdivided portions of Lot Nos. 1234A, 1234B, 1234C,
and 4321, the subject matter of the above-captioned case;

3. That the Intervenors are asserting a public right to

due process and equal protection of the laws under Section
1 of Article III of the 1987 Constitution, which right stands
to be violated by the promulgation last 13 July 2018 of the
Decision of this Honorable Court in the above-captioned
case.

4. That the Intervenors have legal interest in the

matter in litigation, or in the success of the complainant, or
is so situated as to be adversely affected by a distribution or
other disposition of the parcel of lands, subject matter of the
above-captioned case;

5. That this intervention will not, in the least, unduly

delay or prejudice the adjudication of the rights of the
original parties in the case; and

6. That the Intervenors’ rights can be fully protected

in this proceeding rather than by filing a separate
proceeding.

PRAYER

WHEREFORE, the intervenors most respectfully request

that this Honorable Court grant the foregoing Motion For
Intervention and allow the intervention of herein movants in
the above-mentioned case.

Such other reliefs that are just and equitable under the
premises are likewise prayed for.

Makati City for the City of Manila.

18 November 2018.

ANDY WELL
Counsel for Intervenors
Roll of Attorneys No. 46999
IBP No. 249671; 1-4-2018; Makati City
PTR No. 5402296; 1-5-2018; Makati City

15th Floor ATLAS 3000 Building

Salcedo Village
Makati City
 NOTICE OF HEARING

The Clerk of Court

First Division
Supreme Court

Kindly submit the foregoing Motion for Leave to

Intervene for the consideration of the Court immediately
upon receipt hereof.

ANDY WELL

THE SOLICITOR GENERAL

Office of the Solicitor General
555 Amorsolo St., Legaspi Village,
Makati City 1237

SECRETARY EMILY BLONDE

Department of Environment and Natural Resources
DENR Compound
Visayas Ave., Quezon City 1100

DOMINIQUE BROWN
Counsel for Private Respondent
105 Paseo de Roxas, 1226 Makati City

Please take notice that the foregoing Motion for Leave

to Intervene is submitted for the consideration of the Court
immediately upon receipt hereof.

ANDY WELL
 EXPLANATION

Copies of this Motion for Leave to Intervene were filed

and served by registered mail to this Honorable Court and
the public and private respondents, respectively, due to
lackof personnel and material time to effect personal
service.

ANDY WELL

Copies Furnished:

THE SOLICITOR GENERAL

Office of the Solicitor General
555 Amorsolo St., Legaspi Village,
Makati City 1237

SECRETARY EMILY BLONDE

Department of Environment and Natural Resources
DENR Compound
Visayas Ave., Quezon City 1100

DOMINIQUE BROWN
Counsel for Private Respondent
105 Paseo de Roxas, 1226 Makati City