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    Motion For Issaunce of Writ of Execution

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    Desi Derata
    This document is a motion filed in a municipal trial court in Zamboanga City, Philippines requesting the issuance of a writ of execution. It summarizes a previous court decision in favor of the plaintiff, Lucia Vicente, ordering the defendants to vacate the subject property, pay rent, and attorney's fees. It states that the decision became final and executory on January 28, 2021, but the defendants have not complied. The motion asks the court to issue a writ of execution to enforce the previous judgment.

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    Motion For Issaunce of Writ of Execution

    Uploaded by

    Desi Derata
    163 views3 pages
    This document is a motion filed in a municipal trial court in Zamboanga City, Philippines requesting the issuance of a writ of execution. It summarizes a previous court decision in favor of the plaintiff, Lucia Vicente, ordering the defendants to vacate the subject property, pay rent, and attorney's fees. It states that the decision became final and executory on January 28, 2021, but the defendants have not complied. The motion asks the court to issue a writ of execution to enforce the previous judgment.

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    Motion for Issaunce of Writ of Execution

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    This document is a motion filed in a municipal trial court in Zamboanga City, Philippines requesting the issuance of a writ of execution. It summarizes a previous court decision in favor of the plaintiff, Lucia Vicente, ordering the defendants to vacate the subject property, pay rent, and attorney's fees. It states that the decision became final and executory on January 28, 2021, but the defendants have not complied. The motion asks the court to issue a writ of execution to enforce the previous judgment.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    163 views3 pages

    Motion For Issaunce of Writ of Execution

    Uploaded by

    Desi Derata
    This document is a motion filed in a municipal trial court in Zamboanga City, Philippines requesting the issuance of a writ of execution. It summarizes a previous court decision in favor of the plaintiff, Lucia Vicente, ordering the defendants to vacate the subject property, pay rent, and attorney's fees. It states that the decision became final and executory on January 28, 2021, but the defendants have not complied. The motion asks the court to issue a writ of execution to enforce the previous judgment.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 3

    Republic of the Philippines

    MUNICIPAL TRIAL COURT IN CITIES


    Ninth Judicial Region
    Branch 2
    Zamboanga City
    -oOoOo-

    LUCIA VICENTE,
    Plaintiff,

    versus CIVIL CASE No. 7683

    CAROLINA SACRO, NORMA GARINA, For


    MICHAEL MATUTES, BOY JACINTO,
    BRIGIDA TAYCO, and all other RECOVERY OF POSSESSION
    occupants in the property covered by WITH DAMAGES
    TCT No. 129-2016000707,
    Defendants.
    x-----------------------------------------x

    MOTION FOR ISSUANCE OF WRIT OF EXECUTION


    PLAINTIFF LUCIA VICENTE, through the undersigned counsel and
    unto this Honorable Court respectfully submits this Motion for Issuance of
    Writ of Execution and avers the following, to wit-

    1. That on September 2, 2020, the Honorable Court rendered a


    decision, the dispositive portion of the same reads-

    “WHEREFORE, the Court renders JUDGMENT in favor of the


    Plaintiff directing the defendants, their heirs, assigns, representatives
    and/or any person acting for and in their behalves to:

    a. Immediately vacate the subject properties, and to


    demolish/dismantle all their houses and other structures on
    the properties; should the defendants refuse to comply, the
    plaintiff may demolish/dismantle them at the expense of
    the defendants.

    b. Pay reasonable rentals of the use and occupation of the


    subject properties at Php 1,000.00 per month from July
    2016 for each of the defendants; and

    c. Pay Php 15,000 as Attorney’s fees.

    SO ORDERED.”
    2. That on January 28, 2021, the Plaintiff, through the undersigned
    counsel, received a copy of the Certificate of Finality of Judgment
    stating among others that, xxx there being no motion for
    reconsideration nor other modes of appeal availed by the
    defendants, the DECISION dated September 2, 2020, of this Court, on
    September 17, 2020, became FINAL and EXECUTORY;

    3. Up to this date, Defendants have not complied with the Judgment


    rendered by the Honorable Court.

    WHEREFORE, premises considered, it is most respectfully prayed that


    a Writ of Execution be issued to implement the judgment of this
    Honorable Court dated September 2, 2020.

    Such other equitable and just reliefs are likewise prayed for.

    RESPECTFULLY SUBMITTED. 19 February 2021, City of Zamboanga,


    Philippines.

    DESIREE VON ENRIQUEZ-TORRES


    Counsel for Plaintiff
    Roll No. 67175; 05/24/17
    IBP No. 120908; 12/16/2020; ZAMBASULTA
    PTR No. 2173446; 01/05/2021; ZC
    MCLE Compliance No. VI-0014584
    until April 14, 2022
    NOTICE OF HEARING

    THE BRANCH CLERK OF COURT

    Greetings!

    Please take notice that undersigned counsel is submitting the


    foregoing motion for the resolution of the Honorable Court without further
    oral arguments.

    Zamboanga City, 19 february, 2021.

    Atty. Desiree Von Enriquez-Torres

    COPY FURNISHED:

    ATTY. RHEA DOLL B. GONZALO/ ATTY. JOHN PHILIP DELOTINA


    Counsel for Defendants
    Public Attorney’s Office
    Hall of Justice, Zamboanga City

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