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Republic of the Philippines

Fourth Judicial Region


MUNICIPAL TRIAL COURT
Cainta, Rizal

MYRNA DE BELEN,
Plaintiff,
CIVIL CASE No. 16-0410
-versus- For: Execution of Barangay
Agreement
MIRAFLOR GUTIERREZ,
Defendant.
x--------------------------------------x

MOTION FOR EXECUTION

COMES NOW, plaintiff, by herself, unto this Honorable


Court, most respectfully states, THAT:

1. On 27 June 2017, both parties entered into a compromise


agreement to settle the dispute amicably.

2. This Honorable Court decided this case based on the


parties’ compromise agreement1.

3. However, defendant failed to comply with the terms and


conditions of the agreement. Defendant is obliged to pay plaintiff
an amount of Php 50,000.00 on installment basis. Every 15th and
30th of the month, defendant must deliver Php 500.00 before the
Honorable Court until the entire obligation is fully paid.

4. In case the defendant fails to pay 3 installment payments,


plaintiff is entitled for a Writ of Execution of the Judgment on
Compromise Agreement.

5. Defendant in this case failed to pay more than 3


installment payments. Also, she never repudiated nor appealed
the subject Decision on Compromise.

1 Decision based on Compromise – 27 June 2017, Mynra De Belen vs Miraflor Gutierrez

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PRAYER

WHEREFORE, premises considered, it most respectfully


prayed before this Honorable Court that a WRIT OF
EXECUTION be issued for the satisfaction of the Decision dated
27 June 2017.

Other reliefs, just and equitable, under the circumstances


are likewise prayed for.

RESPECTFULLY SUBMITTED.

Cainta, Rizal. 22 February 2018

MYRNA DE BELEN
Plaintiff

NOTICE OF HEARING

Clerk of Court
Municipal Trial Court
Cainta, Rizal

Miraflor Gutierrez
318 Irma St., Marick Subd.,
Cainta, Rizal

GREETINGS:

Please be informed that the foregoing Motion will be


submitted for the consideration and approval of this Honorable
Court on 5 March 2018 at 8:30 AM.

MYRNA DE BELEN
Plaintiff

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EXPLANATION

Due to distance, time constraint and lack of staff, this


Motion was furnished through registered mail, instead of personal
service.

MYRNA DE BELEN

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