REPUBLIC OF THE PHILIPPINES

TH
JUDICIAL REGION
MUNICIPAL TRIAL COURT IN CITIES
BRANCH
CEBU CITY
REPUBLIC OF THE PHILIPPINES,
Complainant,
-versus- CRIMINAL CASE NO. 1254684-R
FOR: BP 22
MA. TECCCC CCCCCCCCC,
Accused.
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MOTION TO REVIVE CRIMINAL ACTION AND FOR THE ISSUANCE OF WRIT OF EXECUTION ON
THE COMPROMISE AGREEMENT WITH FORMAL ENTRY OF APPEARANCE
Complainant, by counsel to this Honorable Court respectfully states:
1. On August 24 2015, the Honorable Court issued an Order in the case THE PEOPLE OF
THE PHILIPPINES VS. MA. XXXXXXXXXX with criminal case no. 125468-R, the Order as
Annex A which reads:

The parties submitted to this Court for approval a Compromise Agreement dated
August 14, 2019, which they have entered before the Philippine Mediation Center with
the assistance of Mediator J Lopoldo, the terms and conditions of which read as follows:
XXX
2. In par. 1 of the aforesaid Compromise Agreement states that: The Defendant hereby
acknowledged her obligation of THIRTY SEVEN THOUSAND FOUR HUNDRED FORTY PESOS ONLY
(P37,440.00) and is willing to pay the said financial obligation to the Complainant in the
following manner:
a. Pay TEN THOUSAND PESOS (P10,000.00) on the 28 th day of August 2015;
b. Pay FIVE THOUSAND PESOS (P5,000.00) on every last Friday of the succeeding
months until the said obligation will be fully paid.
c. All payments shall be made in cash at the office of PJH LENDING CORPORATION with
3. That the total amount paid by the accused was only TWENTY FIVE THOUSAND PESOS
(P25,000.00) and has the balance of Twelve Thousand Four Hundred Forty Pesos
(P12,440.00);

4. To date, accused has never paid again for her monthly obligation to CORPORATION
CORPORATION;

5. It bears stressing that par.2 of the aforesaid Compromise Agreement states that: In case
of failure to pay three (3) consecutive monthly installments, the remaining obligation shall
become due and demandable and entitle plaintiff to the issuance of Writ of Execution.
WHEREFORE, premises considered, it is respectfully prayed that the Writ of Execution be issued against
the defendants, ordering them to pay to Complainant the Total obligation in the amount of Twelve
Thousand Four Hundred Forty Pesos (P12,440.00) representing the balance of her obligation and
filing fee of ONE THOUSAND FIVE HUNDRED FIFTEEN PESOS (P1,515.00).

Other just and equitable reliefs are likewise prayed for.

City of Cebu, 28 January 2017.

ATTY. Mariano Dizon

Counsel for Complainant
MJ Cuenco Ave. Cebu City

WITH MY CONFIRMITY:

PROSECUTOR JJJJJJJJJJJJJJJ
CEBU CITY PROSECUTOR

NOTICE OF HEARING

Accussed

Greetings:

Please submit the foregoing motion for consideration and approval of the Honorable Court on
February 17, 2019 at 8:30 a.m. or at such time and date as may be convenient to the Honorable Court.

EXPLANATION
Copy of this Motion is sent to the Accused through registered mail due to the distance. Thank
you.

ATTY. DIZON
Counsel for Complainant

Copy furnished:

Registry receipt:_____________
Mailed on: _________________