National Capital Judicial Region

Metropolitan Trial Court

Quezon City, Branch 33

BECKY N. POE,
Plaintiff,
Civil Case No. 567977
FOR: COLLECTION FOR A SUM
OF MONEY WITH DAMAGES
- versus -

MA. MERCEDES GO,

Defendant
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - -x

MOTION FOR EXECUTION

Plaintiff, by counsel and unto this Honorable Court, most respectfully states:

That on 20 March 2019, the Honorable Court rendered decision on the

above-captioned case, ordering as follows:

WHEREFORE, PREMISES CONSIDERED, it is respectfully

prayed to this Honorable Court the dismissal of the complaint for lack of
merit with costs against the plaintiff; and that the defendant’s compulsory
counterclaim be granted, i.e., moral damages of One Hundred Thousand
Pesos (₱105,000.00), attorney’s fees of Twenty-Thousand Pesos
(₱30,000.00), and Three Thousand Pesos (₱5,000.00) per court appearance
and costs of suit.

That inquiry into the records of this case with this Honorable Court shows
that no appeal has been taken from the said decision after it has been rendered by
the Honorable Court;
That the reglementary period for appeal has already expired, and said
decision is now final, unappeasable and executory.
 
PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that a

Writ of Execution be issued in the above-captioned case ordering the Sheriff to
execute the Decision dated 20 March 2019.
Respectfully submitted
10 April 2019, Quezon City
 ATTY. STEPHANIE MANI
Counsel for Plaintiff
Mani Law Office, 14th Bldg., Quezon Ave, Quezon City
Roll of Attorney;s No. 63321
PTR NO. 654761, 01/06/14, Quezon City
IBP NO. 198456, 01/04/14, Quezon City
MCLE Comp. No. IV-0009986, 01/02/14

VERIFICATION AND CERTIFICATION

JURAT