Republic of the Philippines

National Capital Judicial Region

 METROPOLITAN TRIAL COURT
Branch LXIII (63)
Makati City

Pedro Sanchez
Plaintiff,

- versus -                                                                

Juan Santiago,
Defendant.
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Civil Case No 123456

FOR: Recovery of Possession

MOTION FOR EXECUTION OF JUDGMENT

          Plaintiff, by counsel and unto this Honorable Court, respectfully states:

1.    That judgment was rendered by this Honorable Court in favor of the plaintiff on April 3, 2023;

2.    That said judgment was duly received by the defendant on April 5, 2023 as shown in the registry
return card;
3. Plaintiff is the lawful and registered owner of a parcel of land identified as Lot 143 a total area of
FOUR HUNDRED SIXTY TWO (462) square meters, more or less, situated at Brgy. 123
Makati City covered by ORIGINAL CERTIFICATE OF TITLE (OCT) NO. 3698522.
4. Defendants are casting doubts on the title and interest of the Plaintiff over Lot 6987-D-1, 7896541
because they are claiming ownership over said parcel and thus disturbing the rights and interest
of the Plaintiff over said parcel of land.
5.    That up to the present, the defendant had not filed any motion for reconsideration, hence the
decision to recover the land has become final and executory.

         WHEREFORE, it is respectfully prayed that an order be issued by this Honorable Court

for a writ of execution of said judgment.
  
  Makati City, Philippines. May 5, 2023.

                                                                         ATTY. Yud Po
                                                                         Counsel for Plaintiff
 NOTICE OF HEARING

THE BRANCH CLERK OF COURT

MeTC - Branch 63
Makati City

ATTY. Wey Yu
Counsel for the Defendant
5789 Zamora Street, Pasay City 

Greetings!
      
Please take notice that the undersigned counsel will submit the foregoing Motion for
Execution to the Honorable Court on May 25, 2023 at 8:30 in the morning for its favorable
consideration and approval.

                                           
Copy furnished by registered mail:
     
ATTY. ABC
Counsel for the Defendant
1234 Zamora Street, Pasay City

EXPLANATION

        Due to lack of messengerial services to effect personal service, a copy of the foregoing
motion was sent to defendant's counsel through registered mail.