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    Motion To Fix Supersedeas Bond To Stay Execution-Seguro vs. Baloran

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    Consigliere Tadili
    This is a draft of a motion to fix supersedeas bond and to stay execution of judgment in an unlawful detainer case. This is filed with the municipal trial court if the case was decided against the defendant.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Motion To Fix Supersedeas Bond To Stay Execution-Seguro vs. Baloran

    Uploaded by

    Consigliere Tadili
    2K views2 pages
    This is a draft of a motion to fix supersedeas bond and to stay execution of judgment in an unlawful detainer case. This is filed with the municipal trial court if the case was decided against the defendant.

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    Motion to Fix Supersedeas Bond to Stay Execution-Seguro vs. Baloran Copy

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    This is a draft of a motion to fix supersedeas bond and to stay execution of judgment in an unlawful detainer case. This is filed with the municipal trial court if the case was decided against the defendant.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    2K views2 pages

    Motion To Fix Supersedeas Bond To Stay Execution-Seguro vs. Baloran

    Uploaded by

    Consigliere Tadili
    This is a draft of a motion to fix supersedeas bond and to stay execution of judgment in an unlawful detainer case. This is filed with the municipal trial court if the case was decided against the defendant.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Republic of the Philippines

    MUNICIPAL TRIAL COURT


    Second Judicial Region
    Gattaran, Cagayan
    SPS. NICOLAS SEGURO
    ANDSEVERINA SEGURO,

    Plaintiffs,

    CIVIL CASE NO. 3099


    FOR:

    -versusSPS. ROGELIO BALORAN


    AND ELBELITA BALORAN
    Defendants.
    x------------------------x

    UNLAWFUL
    DETAINER AND
    DEMOLITION OF
    BUILDING

    MOTION TO SUSPEND THE EXECUTION OF THE FINAL


    ORDER AND TO SET THE SUPERSEDEAS BOND
    Movants thru counsel and unto this Honorable Court, most
    respectfully moves to suspend the execution of Honorable Courts
    decision dated August 28, 2015 during the pendency of appeal,
    and alleges:
    1. That the decision orders the defendants to 1) vacate the
    portion occupied by them containing an area of 365 sq.
    meters; 2) demolish a portion of their house occupying the
    land in dispute; 3) pay to plaontiffs P100.00 per month as
    reasonable compensation for use and enjoyment of the
    property from date of Judicial Demand or from date of
    receipt of Summons on August 3, 2011; 4) Pay plaintiffs
    Attorneys Fees in the amount of P20,000.00 and
    appearance fees of P1,000.00 for every hearing; and 5) pay
    the costs.
    2. That in the even that the defendants prevail on their appeal,
    the orders of the Honorable Court would cause irreparable
    injury to the defendants considering that defendants house
    is made of concrete and the defendants had spent
    considerable amount in erecting their house;
    3. That the defendants filed the notice of appeal within the
    period allowed to file an appeal;
    4. That the defendants requests the execution of the final
    order to be suspended during the appeal; and
    Page 1 of 2

    5. That the defendants request this Honorable Court to fix the


    supersedeas bond necessart to stay the execution of
    judgment.
    WHEREFORE, PREMISES CONSIDERED, the defendants pray
    that this Honorable Court enter order:
    1. Suspending execution of the final order of the court dated
    August 28, 2015;
    2. Directing the plaintiffs not to take any steps to enforce or
    execute the judgment until all appeals in this case have
    been exhausted;
    3. Fixing the amount of supersedeas bond necessary to stay
    the execution under the rules; and
    4. To grant the defendants other reliefs the Honorable Court
    may deem just and proper under the circumstances.
    Aparri, Cagayan for Gattaran, Cagayan. August 17, 2015.
    TUMARU AND TUMARU LAW OFFICES
    Suite 115 Ryan Mall, Rizal St., Centro 14
    Aparri, Cagayan
    By:

    5664938/01-05-15
    Aparri, Cagayan

    09174952763

    RAMON V. TUMARU, JR.


    IBP No. 946710/01-05-15
    Tuguegarao City
    PTR
    No.
    Attorneys Roll No. 19313
    MCLE Compliance No. IV-13106/03-04-13
    Email add: [email protected]
    Tele-Fax No. (078) 888-2943/CP #:

    Copy furnished:
    ATTY. RONALD A. TOMANENG
    De Rivera St., Centro 12,
    Aparri, Cagayan

    Page 2 of 2

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