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. x------------------------------------------ x
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