WRIT OF EXECUTION COMES NOW PLAINTIFF, through the undersigned counsel, unto this Honorable Court, most respectfully avers that: 1. On January 11, 2016, the Plaintiff received a copy of the Decision of the Honorable Court of Bacoor, the dispositive portion of which reads: ACCORDINGLY, as prayed for, judgment is hereby rendered: 1. ) Ordering the defendant to pay the sum of Five Hundred Seventy Eight Thousand Two Hundred Fifty-Six Pesos and 84/100 n(P578,256.84) plus 3% interest per month as stated in the Amicable Settlement, to be reckoned from the time of extrajudicial demand made on 23 October 2013 until fully paid; 2. ) Ordering the defendant to pay the plaintiff the amount
of
(P35,000.00)
Thirty as
Five
attorneys
Thousand fees
plus
Pesos Four
Thousand Pesos (P4,000.00) per appearance
3. ) Ordering defendants to pay the plaintiff the cost of suit. SO ORDERED
2. Section 1, Rule 39 of the Rules of Civil Procedure
provides that: Execution shall issue as a matter of right, or motion, upon a judgment or order that disposes of the action or proceeding upon the expiration of the period to appeal therefrom if no appeal has been duly perfected. 3. It is a remedy afforded for a satisfaction of a judgment. Its object being to obtain satisfaction of the judgment on which the writ is issued. 1
RELIEF WHEREFORE,
premises
considered,
it
is
most
respectfully prayed of this Honorable Court to forthwith issue
a writ of execution for the implementation of its January
11, 2016 Decision issued in connection with the abovecaptioned case.
Other reliefs and remedies, which may be considered just and equitable under the above-circumstances, are likewise prayed for. RESPECTFULLY SUBMITTED. Makati City, for Bacoor, Cavite City 28 July 2015.
JC YRREVERRE LAW FIRM
Counsel for Plaintiff Unit 2307 Cityland 10, Tower 1, H.V. Dela Costa cor. Valero Sts., Salcedo Village, Makati City 1 G.R. No. 129713, (December 15, 1999)
Email add: jcygroup@yahoo.com
Tel. Nos. 893-9296/817-2464 By: ATTY. ALEJANDRO G. YRREVERRE, JR. Attorneys Roll No. 38183 PTR No. 4752040; 1-06-2015; Makati IBP Lifetime Member No. 02826 MCLE Compliance No. IV-0007235 Issued on 08-2-2012 in Pasig City COPY FURNISHED AND NOTICE OF HEARING: THE BRANCH CLERK OF COURT Regional Trial Court Pasig City, Branch 268 ATTY. REYNALDO S. SAMSON Counsel for the Defendant 5 Cepeda Street, Concepcion I Marikina City GREETINGS: Please submit the forgoing motion immediately upon receipt hereof for the consideration and approval of the Honorable Court on _______________ at _____ in the morning/afternoon, WITH NO FURHTER ARGUMENTS AND APPEARANCE.
ALEJANDRO G. YRREVERRE, JR.
EXPLANATION OF MODE OF SERVICE
In accordance with Section 11, Rule 13 of the New Rules on
Civil Procedure, copies of the foregoing Reply were served by way of [___] personal service and/or [___] registered mail to the above addressee/defendants due to the distance and lack of personnel to undertake personal service.