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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 .
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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.


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[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


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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