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Motion For Execution - Ejectment

This document is a motion for execution filed in the Metropolitan Trial Court of Manila, Branch 13. The plaintiff, Perla Espeno Morales, represented by Adoracion Espeño Majadillas, is requesting a writ of execution to enforce a compromise agreement approved by the court on October 26, 2016. Under the agreement, the defendant Maricel Obien agreed to vacate the leased premises by January 31, 2017, but failed to do so. The plaintiff is asking the court to issue a writ of execution to enforce the decision and compel the defendant to vacate the premises.

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ILANIE MALINIS
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2K views2 pages

Motion For Execution - Ejectment

This document is a motion for execution filed in the Metropolitan Trial Court of Manila, Branch 13. The plaintiff, Perla Espeno Morales, represented by Adoracion Espeño Majadillas, is requesting a writ of execution to enforce a compromise agreement approved by the court on October 26, 2016. Under the agreement, the defendant Maricel Obien agreed to vacate the leased premises by January 31, 2017, but failed to do so. The plaintiff is asking the court to issue a writ of execution to enforce the decision and compel the defendant to vacate the premises.

Uploaded by

ILANIE MALINIS
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


METROPOLITAN TRIAL COURT
City of Manila
Branch 13

PERLA ESPENO MORALES,


Represented by:
ADORACION ESPEO
MAJADILLAS
Plaintiff,
Civil Case No. 191281-CV
- Versus -
For: Ejectment
MARICEL OBIEN, and all
other persons claiming
rights under her,
Defendant.
X * * * * * * * * X

MOTION FOR EXECUTION

COMES NOW, the Plaintiff, in the above-entitled case,


by and through the Undersigned Counsel and unto this
Honorable Court, most respectfully avers:

1. That on the 26th of October 2016, the Honorable


Court rendered its Decision based on the Parties
Compromise Agreement approving said Compromise
Agreement dated: September 28, 2016;

2. That defendant failed and refused to vacate the


subject leased premises on January 31, 2017, thus have
failed to comply with the Compromise Agreement to
vacate the leased premises on said date;

3. That defendant remains obstinate as it


continuously and persistently occupies the subject
premises and refuses to surrender and/or turn over
physical possession thereof to Plaintiff;

4. That there is a paramount necessity for the


Issuance of a Writ of Execution to enforce the parties
compromise agreement, most pertinently on the bounded
undertaking of defendant to vacate the subject premises
on January 31, 2017.

P R A Y E R
WHEREFORE, premises considered, it is most
respectfully prayed of this Honorable Court that:

a. This Motion be given its due weight and


credence;

b. A Writ of Execution be issued to implement the


Decision of the Honorable Court dated: 26 th day of October
2016, to effect the vacation of defendant and/or all
persons claiming rights under her from the subject
premises.

Plaintiff prays for other reliefs and remedies just and


equitable under the premises.

City of Manila, February 8, 2017.

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