MOTION TO WITHDRAW

COMES NOW, the undersigned counsel, unto the Honorable Court, most
respectfully states:

1.That the undersigned counsel has already terminated his attorney-client

relationship with the Defendant _____________, particularly because of the
latter's deliberate failure to pay the fees for the undersigned's legal services
despite repeated requests for payment and repeated promises to pay, in
violation of the Defendant's Retainer Contract with the undersigned counsel;

2.That the statement of accounts of the undersigned counsel merely fell on

deaf ears and not a single centavo was paid to this date by the said
Defendant contrary to all its representations;

3.That the undersigned counsel's previous request for said Defendant to give
consent and conformity to the undersigned counsel's Motion for Withdrawal
was never acted upon to this date;

4.That in view of the foregoing reasons, the undersigned counsel could no

longer adequately fulfill his obligations as legal counsel for the said
Defendant;

5.That Rule 22.01 par. (f) of the Code of Professional Responsibility states
that a lawyer may withdraw his services when the client deliberately fails to
pay the fees for the services or fails to comply with the retainer agreement;

6.That there is a need to protect the members of the legal profession from
clients who take advantages of their professional services. In fact, the
Honorable Supreme Court had the occasion to state that:

"Counsel, any counsel, if worthy of his hire, is entitled to be fully

recompensed for his services. With his capital consisting solely of his brains
and with his skill, acquired at tremendous cost not only in money but in the
expenditure of time and energy, he is entitled to the protection of any
judicial tribunal against any attempt on the part of the client to escape
payment of his fees. It is indeed ironic if after putting forth the best that is
in him to secure justice for the party he represents, he himself would not get
his due. Such an eventuality this Court is determined to avoid. It views with
disapproval any and every effort of those benefited by counsel's services to
deprive him of his hard-earned honorarium. Such an attitude deserves
condemnation."(Albano vs. Coloma, 21 SCRA 411).
7.As such, undersigned most respectfully requests that he be allowed by this
Honorable Court to withdraw his appearance in this case as Counsel for the
Defendant _____________ without the latter's express conformity.

PRAYER
WHEREFORE, premises considered, undersigned counsel most respectfully
prays that he be allowed to withdraw his appearance in this case as counsel
for the Defendant _____________, dispensing with the latter's express
conformity, and that he be relieved of all his responsibilities relative to this
case.

Other reliefs just and equitable under the premises are likewise prayed for.

_____________, Philippines, __Date__.

(COUNSEL)

(NOTICE OF HEARING)

(EXPLANATION)

COPY FURNISHED:

OPPOSING COUNSEL