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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

MOTION FOR ISSUANCE OF


WRIT OF EXECUTION
COMES
NOW
PLAINTIFF,
through
the
undersigned counsel, unto this Honorable Court,
most respectfully avers that:
1. On January 11, 2016, the Plaintiff received a copy of the
Decision of the Honorable Court of Bacoor, the dispositive
portion of which reads:
ACCORDINGLY, as prayed for, judgment is hereby
rendered:
1. ) Ordering the defendant to pay the sum of Five
Hundred Seventy Eight Thousand Two Hundred
Fifty-Six Pesos and 84/100 n(P578,256.84) plus
3% interest per month as stated in the Amicable
Settlement, to be reckoned from the time of
extrajudicial demand made on 23 October 2013
until fully paid;
2. ) Ordering the defendant to pay the plaintiff the
amount

of

(P35,000.00)

Thirty
as

Five

attorneys

Thousand
fees

plus

Pesos
Four

Thousand Pesos (P4,000.00) per appearance


3. ) Ordering defendants to pay the plaintiff the cost
of suit.
SO ORDERED

2. Section 1, Rule 39 of the Rules of Civil Procedure


provides that:
Execution shall issue as a matter of right, or motion, upon a
judgment or order that disposes of the action or proceeding
upon the expiration of the period to appeal therefrom if no
appeal has been duly perfected.
3. It is a remedy afforded for a satisfaction of a
judgment. Its object being to obtain satisfaction of the
judgment on which the writ is issued. 1

RELIEF
WHEREFORE,

premises

considered,

it

is

most

respectfully prayed of this Honorable Court to forthwith issue


a writ of execution for the implementation of its January

11, 2016 Decision issued in connection with the abovecaptioned case.


Other reliefs and remedies, which may be considered
just and equitable under the above-circumstances, are
likewise prayed for.
RESPECTFULLY SUBMITTED.
Makati City, for Bacoor, Cavite City 28 July 2015.

JC YRREVERRE LAW FIRM


Counsel for Plaintiff
Unit 2307 Cityland 10,
Tower 1, H.V. Dela Costa cor. Valero Sts.,
Salcedo Village, Makati City
1 G.R. No. 129713, (December 15, 1999)

Email add: jcygroup@yahoo.com


Tel. Nos. 893-9296/817-2464
By:
ATTY. ALEJANDRO G. YRREVERRE, JR.
Attorneys Roll No. 38183
PTR No. 4752040; 1-06-2015; Makati
IBP Lifetime Member No. 02826
MCLE Compliance No. IV-0007235
Issued on 08-2-2012 in Pasig City
COPY FURNISHED AND NOTICE OF HEARING:
THE BRANCH CLERK OF COURT
Regional Trial Court
Pasig City, Branch 268
ATTY. REYNALDO S. SAMSON
Counsel for the Defendant
5 Cepeda Street, Concepcion I
Marikina City
GREETINGS:
Please submit the forgoing motion immediately upon receipt
hereof for the consideration and approval of the Honorable
Court
on
_______________
at
_____
in
the
morning/afternoon, WITH NO FURHTER ARGUMENTS AND
APPEARANCE.

ALEJANDRO G. YRREVERRE, JR.


EXPLANATION OF MODE OF SERVICE

In accordance with Section 11, Rule 13 of the New Rules on


Civil Procedure, copies of the foregoing Reply were served
by way of [___] personal service and/or [___] registered
mail to the above addressee/defendants due to the distance
and lack of personnel to undertake personal service.

ALEJANDRO G. YRREVERRE, JR.

C0205/var/www/apps/conversion/tmp/scratch_2/322693487.docx

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