Republic of the Philippines

Sixth Judicial Region

Regional Trial Court
Branch 44
-oOo-

CHING HONG GI/GLORIOUS

HARDWARE,
Plaintiff,

-versus- Civil Case No. 21-420619

For: “Collection of Sum of
Money with Damages”

SPOUSES OSCAR SUYO AND

MARIA SUYO
Defendants/Third-Party Plaintiffs,
x----------------------------------------------x

-versus-

RAUL REYES,
Third-Party Defendant.
x----------------------------------------------x

JOINT MOTION FOR APPROVAL OF COMPROMISE

AGREEMENT

Plaintiff Glorious Hardware/Ching Hong Gi and Intervenor ABC

Corporation, through the undersigned counsels, respectfully state that:

1. Glorious Hardware/Ching Hong Gi is the Plaintiff in Civil

Case No. 21-420619 for Collection of Sum of Money with
Damages against the Spouses Oscar Suyo and Maria Suyo;

2. ABC Corporation is a manufacturer and supplier of

construction materials, from whom Plaintiff purchased on credit,
several construction and waterproofing materials used in the
Defendant Spouses’ building construction;

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 3. ABC Corporation filed a Complaint in Intervention against
Plaintiff Glorious Corporation/Ching Hong Gi in the above-
entitled case for the collection of sum of money worth Five
Hundred Thousand Pesos (Php 500,000.00);

4. To liberate each other from any current and future burden,

the parties have decided to amicably settle the dispute between
them by executing a Compromise Agreement (copy of which is
hereto attached as Annex “A”) with the significant terms and
conditions as follows:

xxx xxx xxx

a. The Plaintiff shall pay ABC Corporation the amount of Five

Hundred Thousand Pesos (Php 500,000.00) in cash;

b. Upon payment and acceptance of ABC Corporation of the

abovementioned payment, ABC Corporation shall issue an
acknowledgement receipt of the said payment;

c. ABC Corporation shall release the Plaintiff from its

obligation and desist from pursuing its cause against Plaintiff
Glorious/Ching Hong GI, specifically its Complaint in
Intervention, and other future claims, except for purposes of
execution in case of default.

xxx xxx xxx

5. The undersigned parties agree that the approval of the

Compromise Agreement by the Court shall put an end to the
litigation as between Plaintiff Glorious Hardware/Ching Hong Gi
and Intervenor ABC Corporation, except for purposes of
execution in case of default.

PRAYER

Wherefore, premises considered, the parties respectfully pray

that judgment be rendered approving the Compromise Agreement and
ordering compliance therewith.

All other relief and remedies as may be fair and equitable under
the premises are also prayed for.

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SO ORDERED.
November 15, 2021, Bacolod City.

CEDRIC LANCE MIRAVALLES MILITAR

Roll of Attorneys No. 73890
MCLE COC VI-0003383; 06-16-2022
PTR No. 132434; 01-05-2022; Bacolod City
IBP (Lifetime) OR No. 937410; 01-03-17; Negros Occidental Chapter
E-mail: clmilitar@gmail.com

John Emmer S. Gamo

JOHN EMMER S. GAMO
Roll of Attorneys No. 09872
MCLE COC VI-0003369; 06-16-2017
PTR No. 8606484; 01-05-2021; Bacolod City
IBP (Lifetime) OR No. 1052700; 01-03-17; Negros Occidental
Chapter
E-mail: johnemmergamoatty@gmail.com

NOTICE OF HEARING

THE HONORABLE CLERK OF COURT:

Greetings! Kindly submit the foregoing Motion for the kind action
and resolution of the Honorable Court on 17 November 2021. Thank
you.

John Emmer S. Gamo

JOHN EMMER S. GAMO CEDRIC LANCE M. MILITAR

Copy furnished:

VAAPE LAW OFFICES

Counsel for the Defendants
2nd Floor, Unicorn Building
Bacolod City, Negros Occidental
Date: November 15, 2021

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MILITAR AND ASSOCIATES LAW OFFICE
Counsel for the Plaintiff-Intervenor
456 Lacson St., Bacolod City
Date: November 15, 2021

VILLAGANTE AND ASSOCIATES LAW OFFICE

Counsel for the Third-Party Defendant
C.I.T. Bldg., Lacson-Luzuriaga Sts., Bacolod City
Date: November 15, 2021

EXPLANATION

Copy of the foregoing was served to the other parties and filed
with the Honorable Court, respectively, by way of registered mail only
and not by personal service due to distance and time constraints to
effect personal form of service.

John Emmer S. Gamo

JOHN EMMER S. GAMO CEDRIC LANCE M. MILITAR

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