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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


METROPOLITAN TRIAL COURT
Branch 79/121, Las Pinas City

abs MANAGEMENT CORPORATION

CIVIL CASE NO. 9876


Plaintiff, FOR: Unlawful Detainer

-versus-

Helen SACRIZ,
his Assigns and all other persons claiming
rights under him,
Defendant.
x------------------------------------------------------x

MOTION FOR EXECUTION

PLAINTIFF ABC MANAGEMENT CORPORATION, as represented by PRO-


MANAGERS INC., through undersigned counsel and unto this Honorable Court,
respectfully avers that:

1. On June 26, 2018, the Honorable Court issued an Order granting the
plaintiff’s URGENT MOTION of the Compromise Agreement dated October
20, 2017 executed between the parties before the Philippine Mediation
Center in Las Pinas City, including the Decision Based on Compromise
Agreement dated October 20, 2017. Copies of the Order dated June 26,
2018 and the Amended Decision Based on Compromise Agreement dated
October 19, 2015 are attached hereto as ANNEX “A” and “A-1”,
respectively;

2. On January 17, 2019, the Honorable Court issued a Certificate of Finality


certifying that the Decision has already become final and executory. A copy
of the Certificate of Finality dated January 17, 2019 is attached hereto as
ANNEX “B”;

3. Since its finality, the defendant has not complied with the Decision. Hence,
the issuance of a Writ of Execution is proper.

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PRAYER

WHEREFORE, in view of the foregoing, it is most respectfully prayed that a Writ of


Execution be issued to implement the judgment of the Honorable Court dated
October 19, 2015.

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

Paranaque City for Las Pinas City, April 1, 2019.

MANDAUE & ASSOCIATES


Counsel for the Plaintiff
Unit S ABC BLDG
BF Homes Subdivision, Paranaque City 1720

By:

ATTY. JONATHAN SANTOS


PTR No. 17123/ PQUE
IBP No. 06610
Roll No. 56789
MCLE Compliance No. VI-0001234

NOTICE OF HEARING

BRANCH CLERK OF COURT


MeTC Branch 79/121,
Elena Building, Alabang-Zapote Road
Las Pinas City

ATTY. JOANNA AGCAOILE


Counsel for the Defendant
Unit 308, Aurora Arcade
Almanza Uno, Alabang Zapote Road
Las Pinas City

Greetings! Please take note that the undersigned counsel will submit the
foregoing pleading for consideration and approval of the Honorable Court on April
5, 2019 at 8:30 am.

JONATHAN SANTOS

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EXPLANATION

Due to distance and lack of personnel, the service and filing of the instant
pleading were coursed through LBC.

FURNISHED WITH COPIES:

BRANCH CLERK OF COURT


MeTC Branch 79/121,
Elena Building, Alabang-Zapote Road
Las Pinas City

ATTY. JOANNA AGCAOILE


Counsel for the Defendant
Unit 308, Aurora Arcade
Almanza Uno, Alabang Zapote Road
Las Pinas City

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