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    Motion For Writ of Execution-Dannara

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    Jose Bonifacio
    1) The plaintiff filed a motion for issuance of a writ of execution based on a compromise agreement between the plaintiff and defendant from January 2017. 2) Under the agreement, the defendant agreed to pay PHP 280,000 in monthly installments of PHP 10,000, but failed to pay installments for August, September and October 2017. 3) As a result of missing three payments, the plaintiff is requesting a writ of execution to demand the remaining PHP 220,000 owed by the defendant.

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    Motion For Writ of Execution-Dannara

    Uploaded by

    Jose Bonifacio
    329 views4 pages
    1) The plaintiff filed a motion for issuance of a writ of execution based on a compromise agreement between the plaintiff and defendant from January 2017. 2) Under the agreement, the defendant agreed to pay PHP 280,000 in monthly installments of PHP 10,000, but failed to pay installments for August, September and October 2017. 3) As a result of missing three payments, the plaintiff is requesting a writ of execution to demand the remaining PHP 220,000 owed by the defendant.

    Original Description:

    Motion of WE Danarra

    Original Title

    Motion for Writ of Execution-dannara

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    1) The plaintiff filed a motion for issuance of a writ of execution based on a compromise agreement between the plaintiff and defendant from January 2017. 2) Under the agreement, the defendant agreed to pay PHP 280,000 in monthly installments of PHP 10,000, but failed to pay installments for August, September and October 2017. 3) As a result of missing three payments, the plaintiff is requesting a writ of execution to demand the remaining PHP 220,000 owed by the defendant.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    329 views4 pages

    Motion For Writ of Execution-Dannara

    Uploaded by

    Jose Bonifacio
    1) The plaintiff filed a motion for issuance of a writ of execution based on a compromise agreement between the plaintiff and defendant from January 2017. 2) Under the agreement, the defendant agreed to pay PHP 280,000 in monthly installments of PHP 10,000, but failed to pay installments for August, September and October 2017. 3) As a result of missing three payments, the plaintiff is requesting a writ of execution to demand the remaining PHP 220,000 owed by the defendant.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 4

    REPUBLIC OF THE PHILIPPINES

    First Judicial Region


    MUNICIPAL TRIAL COURT
    San Nicolas Ilocos Norte

    ED MAR VINCENT L. BONOAN


    Doing business under the name
    And style of VNV SECURITY AGENCY,
    Plaintiff,

    -versus- Civil Case No. 575


    For: Collection of Sum of Money
    and Damages

    DANARRA CONDUMINIUM
    And CORAZON B. FLORES,
    Defendants.
    x---------------------------------------------------x

    MOTION FOR ISSUANCE OF WRIT OF EXECUTION


    WITH FORMAL ENTRY OF APPEARANCE

    PLAINTIFF, by counsel and to this Honorable Court, most


    respectfully state - that:

    1. That on January 31, 2017, the parties have set their hands and
    affixed their signatures on their Compromise Agreement.

    2. That based on their Compromise Agreement are as follows:

    a. That the defendant in this case admits her civil obligations to


    the Plaintiff in the amount of TW0 HUNDRED EIGHTY THOUSAND
    PESOS (P280,000.00) which is the subject of this case.

    b. That the Defendant shall pay said obligation in the amount of


    TEN THOUSAND (P10,000.00) monthly , beginning upon signing of this
    compromise agreement and every 30th of the month thereafter until full
    payment, and to be deposited to the bank account of the plaintiff .
    2

    c. should the Defendant fail to pay one (1) monthly payment, the
    whole amount of the civil obligation remaining unpaid shall be immediately
    ( become) due and payable and the same be the subject of execution based
    on this Compromise Agreement with legal interest until full payment.

    d. That this Compromise Agreement not being contrary to law and


    public policy.

    3. That on March 24, 2017 the court rendered Judgment on


    Compromise Agreement that the defendant was directed to pay the plaintiff
    the sum of TWO HUNDRED EIGTHY THOUSAND PESOS (Php
    280,000.00) payable on monthly installment basis of TEN THOUSAND
    PESOS (P10, 000.00), commencing from March 9, 2017 and every 30th of
    the month thereafter until full payment, and to be deposited to the bank
    account of the plaintiff. The first installment of P10, 000.00 which was due
    on March 9, 2017, must be deposited in plaintiff’s bank account upon receipt
    of this decision. Should the defendant fail to pay one (1) monthly installment
    the whole amount of the civil obligation remaining unpaid shall immediately
    become due and payable and the same shall be subject of execution based on
    this Compromise Agreement, with legal interest until full payment.

    4. That the defendant paid her obligation on March 9, 2017,


    March 30, 2017 on monthly basis and until the 30 th day of July 2017
    amounting to SIXTY THOUSAND PESOS (Php 60,000.00) and that the
    defendant failed to pay her civil obligation beginning the 30 th day of August,
    September, and October. The bank account of the plaintiff is hereto attached
    as ANNEX “A”. The Defendant failed to pay two (3) months installment,
    Hence, the whole amount of the civil obligation remaining unpaid
    amounting to TWO HUNDRED TWENTY THOUSAND PESOS (Php
    220,000.00) shall be immediately due and demandable and the same shall be
    the subject of execution.

    WHEREFORE, plaintiff most respectfully prays to this Honorable


    Court for issuance of writ of execution.

    Plaintiff prays for such other and further relief just and equitable
    under the circumstances.

    San Nicolas Ilocos Norte, November 14, 2017.


    3

    [Explanation: Copy of this Motion for issuance of Writ of Execution has


    been served on the adverse party and filed by registered mail in view of
    lack of office personnel who can undertake personal service.]

    JAY ROGER BRACEROS


    Collaborating counsel for the Plaintiff
    3/F Boy Construction Bldg.,
    Brgy. 2 San Nicolas, Ilocos Norte 2901
    PTR No. 4352668; 06-07-17; I.N.
    IBP No. 004402; 05-08-17; I.N.
    MCLE Compliance No. – Exempted (Newly Admitted)
    Mobile no. 09256610683

    NOTICE OF HEARING

    THE BRANCH CLERK OF COURT


    Municipal Trial Court
    San Nicolas Ilocos Norte

    ATTY. ANTONIO R. MALASIG


    Suite 401-B, Delta Building
    West Avenue corner Quezon Avenue
    1104 Quezon City

    Greetings:
    Please submit the foregoing motion for issuance of writ of execution
    for resolution of the Honorable Court on Nov 24, 2017 at 2 o’clock in the
    afternoon.

    JAY ROGER BRACEROS


    4

    Copy furnished:

    ATTY. ANTONIO R. MALASIG


    Suite 401-B, Delta Building
    West Avenue corner Quezon Avenue
    1104 Quezon City

    DANARRA CONDOMINIUM CORP.


    Metropolitan Ave. cor. Mola St.
    Makati City

    MS. CORAZON B. FLORES


    Metropolitan Ave. cor. Mola St.
    Makati City

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