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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES
Ninth Judicial Region
Branch 3
Zamboanga City

SPOUSES MARK FRANCIS R. CIVIL CASE NO. SCC-1051-

PABLO and MARYNOR D. PABLO, 15

Plaintiff, -for-

-versus- COLLECTION OF SUM OF

MONEY
MAYCARL M. DEGAMO,
Defendant.
X-----------------------------------------X

MOTION FOR EXECUTION

COMES NOW, Plaintiff through the undersigned counsel unto

this Honorable Court most respectfully states that:

1. On 06 April 2015, this Honorable Court issued a Decision in

the above-entitled case, the dispositive portion of which are
hereunder quoted as follows:

WHEREFORE premises considered, judgment is

rendered in favor of the Plaintiff and against the defendant,
by ordering the latter to:

1. Pay actual damages in the amount of P100,00.00 as the

obligation payable within the period of two (2) years;
2. Defendant agreed to pay the plaintiff the amount of at
least P1,000.00 per month starting on April 30, 2015 and
every 30th day of the month;
3. The payment shall be made to the plaintiffs
representative MARICRIS DE CASTRO MORONES at
37K, Villamaria Maria Drive, Estrada Street, Tetuan, this
city, and plaintiff will issue a receipt for every payment
made by the defendant; and
4. Failure on the part of the defendant MAYCARL M.
DEGAMO to pay any two (2) monthly installments, the
plaintiff may file a writ of execution to enforce the payment
of the unpaid balance of her obligation.

IT IS SO ORDERED, this On 06 April 2015.

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(ORIGINALLY SIGNED)

2. Said Decision has become final and executory;

3. In view of the foregoing, the plaintiff most respectfully prays

of this Honorable Court to issue the Motion for Execution on
the above-entitled case;

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable

Court that a Motion for Execution be issued for the satisfaction of the
Decision issued by the Honorable Court dated On 06 April 2015.

Other reliefs as may be just and equitable under the premises

are likewise prayed for.

City of Zamboanga, Philippines, 28 June 2017.

GIAN PAOLO U. ENRIQUEZ

Counsel for Plaintiff
ENRIQUEZ CAPIN and GAUGANO LAW OFFICES
2nd Floor, LDM Bldg., Pilar St., Zamboanga City
PTR No. 1402788 1/04/17
IBP No. 755895 1/3/17
at Zamboanga City
Roll No. 49871-05/02/05
MCLE Compliance No. III- 0012187-04/13/10
MCLE Compliance No. IV- 0000617-05/11/10
MCLE Compliance No. V- 0002658- 06/19/14
Emailaddress:enriquez.capin.gaugano.law@gmail.com
Telephone Number: (062) 990-1412
Telephone Number: (062) 990-1412

Copy Furnished:
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MAYCARL M. DEGAMO
Zone 3, Socorro Street, Mercedes,
Zamboanga City

NOTICE OF HEARING

The Clerk of Court

MTC Branch 3
Sta. Barbara, Zamboanga City

MAYCARL M. DEGAMO
Zone 3, Socorro Street, Mercedes,
Zamboanga City

GREETINGS:

Please submit the foregoing Motion for Execution for the

consideration and approval on 07 July 2017 at 8:30 o clock in the
morning or as soon as the matter may be heard.

GIAN PAOLO U. ENRIQUEZ

EXPLANATION

It is respectfully manifested that a copy of the foregoing

MOTION FOR EXECUTION is being served to the Defendant via
registered mail with return card due to distance.

GIAN PAOLO U. ENRIQUEZ