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REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
BRANCH 31, QUEZON CITY, PHILIPPINES

JULIAN FLORES and ROSA


FLORES,
Plaintiffs,

-versus- CIVIL CASE NO. 1315

RODY DE ASA and ANA DE


ASA,
Defendants.
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MOTION TO FILE SUPERSEDEAS BOND

COMES NOW, the defendants, through the undersigned


counsel and unto the Honorable Court, most respectfully states that:

1. On April 5, 2021, the Honorable Court rendered a decision in


the above – captioned case finding merit the contention posed
by the plaintiff spouses and ordering the defendant to vacate
the said premises. The same decision of the court was received
by the defendant spouses on April 15, 2021. As proof thereof,
attached is a copy of the decision of the Honorable Court, dated
April 5 ,2021, as Annex “1”;

2. By virtue of the decision of the Honorable Court in the above –


captioned case, the defendant spouses are mandated to vacate
the premises;

3. Considering the intent of the defendant spouses to file an


appeal, they are willing to post the necessary supersedeas
bond, as well as deposit the monthly rentals in order to remain
in the premises subject of the appeal;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of


the Honorable Court that the defendant spouses be allowed to post
the necessary supersedeas bond and pay the monthly rentals
equivalent to their stay in the premises.
Other reliefs, just and equitable, are likewise prayed for.

April 20, 2021, Quezon City, Philippines.

PUBLIC ATTORNEY’S OFFICE


Department of Justice
QUEZON CITY - DISTRICT OFFICE
Quezon City, Philippines
Counsel for the Defendants

BY:

ATTY. JONATHAN PAOLO R.


DIMAANO
Public Attorney II

The Clerk of Court


Metropolitan Trial Court
Branch 31, Quezon City, Philippines

GREETINGS:

Please submit the foregoing motion for the consideration of the


Honorable Court immediately upon receipt hereof.

ATTY. JONATHAN PAOLO R. DIMAANO

CC:

Julian Flores
Rosa Flores
Brgy. Babuyan, Puerto Princesa
Palawan

Atty. Juan Dela Cruz


Juan Dela Cruz Law Office
3rd Floor, ABC Unit
Brgy. Babuyan, Puerto Princesa
Palawan
Counsel for the Plaintiffs

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