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    Motion For Execution

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    edcelquiben
    Anita Siy and Manuel O filed an unlawful detainer case against Herminigildo Manalastas Tolentino. A compromise agreement was reached and approved by the court. However, Tolentino did not comply with the agreement and instead encroached on an adjacent lot. The plaintiffs now move for a writ of execution to enforce the court's decision in their favor based on the non-compliance of the defendant.

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    Motion For Execution

    Uploaded by

    edcelquiben
    285 views2 pages
    Anita Siy and Manuel O filed an unlawful detainer case against Herminigildo Manalastas Tolentino. A compromise agreement was reached and approved by the court. However, Tolentino did not comply with the agreement and instead encroached on an adjacent lot. The plaintiffs now move for a writ of execution to enforce the court's decision in their favor based on the non-compliance of the defendant.

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    Motion for Execution

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    Anita Siy and Manuel O filed an unlawful detainer case against Herminigildo Manalastas Tolentino. A compromise agreement was reached and approved by the court. However, Tolentino did not comply with the agreement and instead encroached on an adjacent lot. The plaintiffs now move for a writ of execution to enforce the court's decision in their favor based on the non-compliance of the defendant.

    Copyright:

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

    Motion For Execution

    Uploaded by

    edcelquiben
    Anita Siy and Manuel O filed an unlawful detainer case against Herminigildo Manalastas Tolentino. A compromise agreement was reached and approved by the court. However, Tolentino did not comply with the agreement and instead encroached on an adjacent lot. The plaintiffs now move for a writ of execution to enforce the court's decision in their favor based on the non-compliance of the defendant.

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    © All Rights Reserved
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    of 2

    REPUBLIC OF THE PHILIPPINES

    THIRD JUDICIAL REGION


    REGIONAL TRIAL COURT
    CITY OF SAN JOSE DEL MONTE, BULACAN
    BRANCH 3

    ANITA SIY & MANUEL O,


    Plaintiffs,

    -versus- CIVIL CASE NO. 008-SJ-2015


    NATURE: UNLAWFUL DETAINER

    HERMINIGILDO MANALASTAS,
    TOLENTINO alias “HERMINILGILDO
    MANALASTAS” and/or “JUN
    TOLENTINO” and claiming rights under him,
    Defendants,

    x-----------------------------------------x

    MOTION FOR EXECUTION

    COMES NOW, ROBERTO R. GAMEZ, by himself, and unto this


    Honorable Court most respectfully avers that:

    1. Plaintiffs ANITA SY and MANUEL O filed a civil case for Unlawful


    Detainer against HERMINIGILDO MALASTAS TOLENTINO
    before this Honorable Court docketed as Civil Case No.: 008-SJ-
    2015. Plaintiffs executed a SPECIAL POWER OF ATTORNEY in
    favor of the undersigned, Said SPA is attached hereto as Annex
    “A”;

    2. On July 20, 2015, a Compromise Agreement was executed


    between the plaintiffs and defendants which was duly approved by
    the Honorable Court on December 7, 2015. The copy of the
    Compromise Agreement dated July 20, 2019 is hereto attached as
    Annex “B”;

    3. Consequently, the instant case was submitted for Decision and


    was decided in favor of the plaintiffs. The case was provisionally
    dismissed on the condition that the parties will faithfully comply
    with the terms and conditions of the Compromise Agreement.
    Copy of the said Decision is hereto attached as Annex “C”;

    4. However, defendants never complied with the terms of the


    agreement despite mutually and voluntarily concurring the same;
    5. Instead of complying, the defendants encroached the adjacent lot
    with a size of 52 sqm more or less.

    6. In view of which, the plaintiffs move for the execution of the


    Honorable Court’s decision in the instant case.

    WHEREFORE, premises considered, it is respectfully prayed that


    a Writ of Execution be issued to implement the Honorable Court ‘s
    Decision dated July 20, 2015.

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

    City of San Jose del Monte, Bulacan. 20 November 2019.

    ROBERTO R. GAMEZ
    Attorney in fact

    NOTICE OF HEARING AND EXPLANATION

    The Honorable Branch Clerk of Court


    Branch 13 – RTC
    Malolos, City
    Bulacan

    HERMINIGILDO M. TOLENTINO
    Blk 12 Ext., Gumaoc West
    City of San Jose del Monte
    Bulacan

    Greetings!

    Please be informed that the undersigned will submit the foregoing


    motion for execution and approval of the Court on ____________ at
    _______________ in the morning, or at the Honorable Court’s most
    convenient time.

    A copy of this Motion was not served personally due to lack of


    personnel to do the same, copy of which was served to the adverse part by
    registered mail with return card.

    Copy Furnished:

    HERMINIGILDO M. TOLENTINO
    Blk 12 Ext., Gumaoc West
    City of San Jose del Monte
    Bulacan

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