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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


METROPOLITAN TRIAL COURT
MANDALUYONG CITY
BRANCH XCIX (99)

RADIOWEALTH FINANCE
COMPANY INC.,
Plaintiff, Civil Case No. 23340

For: Sum of Money


-versus-

ROMIEL M. BALADAD &


JOVELYN P. LEONARDO,
Defendants.
x-------------------------x

MOTION FOR EXECUTION

Plaintiff, by counsel, respectfully states that:

1. On January 13, 2017, a judgment in this initiated case was rendered


by this Honorable Court which copy was received on March 2, 2017,
the dispositive portion of which reads:

WHEREFORE, premises considered, the


Defendants Romiel M. Baladad and Jovelyn P. Leonardo
are hereby ordered to solidarily pay the Plaintiff the total
amount of P228, 739.00 plus 6% legal rate of interest
starting from April 6, 2015 until the finality of this Courts
Judgment. Thereafter, another 6% interest to be imposed
on the final and executor judgment amount until its full
satisfaction pursuant to the Nacar Doctrine.

No pronouncement as to costs.

2. To date, no notice of appeal has been filed by the Defendants nor has
copy thereof been received by Plaintiff RFC. Hence the judgment
became final and executory;
3. The Defendant has not complied with the judgment;

WHEREFORE, premises considered, it is respectfully prayed


that a writ of execution be issued to implement the judgment of the
court dated January 13, 2017.

Mandaluyong City, March 3, 2017.

ATTY. EDRYNE JETH F. JUNTILLA


Legal Department
Radiowealth Finance Company, Inc.
7th Floor DMG Center, DM Guevara St.,
Brgy. Highway Hills, Mandaluyong City
IBP No. 1055126/01-3-2017/Batangas
PTR No. 2553050 /Mandaluyong City/01-09-2017
MCLE Compliance No. N/A
Roll No. 65661

NOTICE OF HEARING

The Branch Clerk of Court


MTC Mandaluyong City, Branch 99

Romiel M. Baladad and Jovelyn Leonardo

Greetings:

Please take notice that the undersigned counsel will submit the
foregoing motion for the consideration and approval of the Court on
March 13, 2017.

ATTY. EDRYNE JETH F. JUNTILLA

Copy furnished by registered mail:

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Romiel M. Baladad and Jovelyn Leonardo
203 F. Sabado St., San Francisco District, Pagdaian City

Note: Registered mail was opted instead of personal service due to


limited manpower.

ATTY. EDRYNE JETH F. JUNTILLA

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