Republic of the Philippines

Regional Trial Court

11th Judicial Region
Davao City
Branch 17

________________

Plaintiffs,
-versus- -for-

____________________ Breach of Contract, etc.

______________________
Defendant.
X- - - - - - - - - - - - - - - - - - - - -X

MOTION FOR EXECUTION

COMES NOW, the defendant, through the Undersigned Counsel, and unto this
Honorable Court, most respectfully states that:

1 – On __________________, the Honorable Court issued a decision based on

a __________________________ which was received by Defendant on
______________. (Attached is the copy of the decision marked as Annex A);

2 – The Plaintiff was ordered to pay Defendant the amount of

__________________ under the following conditions, the decision quoted herein
below in toto:

______________________________________________________

3 - To date, plaintiff ____________ has been remised in their obligation as

they failed to comply with the decision of the Honorable Court;

4 – Plaintiff ____________ last payment was made on ______________, and

their remaining liability to the defendant is _________________. Plaintiff failed to
comply with Paragraph 4 of the decision;

5 – Plaintiff _____________ acted in bad faith as they failed to observe, strictly

abide and perform the terms of the decision.

6 – Defendant prays that a Writ of Execution be issued in their favor under

Section of Rule 39 of the Rules of Court ;

WHEREFORE, premises considered, it is respectfully prayed that this

Honorable Court issue a Writ of Execution in favor of Defendant as the plaintiff
failed to comply with the decision of the Honorable Court.

City of Davao, ______________.