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REPUBLIC OF THE PHILIPPINES

8TH JUDICIAL REGION


Regional Trial Court
Branch 7
Tacloban City

HAVANA O. NANA, Civil Case No: R-TAC-18-


Plaintiff, 00506-CV
FOR: COLLECTION FOR A
SUM OF MONEY WITH
- versus -
DAMAGES

GEMMA T. TRONE,
Defendant.
x-----------------------------------x

MOTION FOR EXECUTION

COMES NOW, the Plaintiff through undersigned counsel and to this


Honorable Court, respectfully states:

1. That on April 1, 2018, the Honorable Court rendered decision on the


above-captioned case, the dispositive portion of which reads:

WHEREFORE, judgment is rendered of plaintiff and against defendant


Gemma T. Trone ordering defendant:

a) To pay plaintiff the amount of P1,000,000.00


representing the principal obligation with 12% interest
per annum from ________ by virtue of the Promissory
Note dated _________________;

b) To pay plaintiff attorneys fees in the amount of 20% of


the sum collected; and

c) To pay costs of suit.

SO ORDERED.

2. That no appeal has been taken from the said decision after it has
been rendered by the Honorable Court;

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3. That the reglementary period for appeal has already expired, and
said decision is now final, unappeallable and executory;

4. The defendant has not complied with the judgment.

WHEREFORE, premises considered, it is respectfully prayed that a


writ of execution be issued to implement the judgment of the Court dated
April 13, 2018.

Tacloban City, Philippines. May 5, 2018.

ATTY. MAKI P. PERA


Counsel for Plaintiff
123, Real Street, Tacloban City
Roll of Attorneys No. 98765
PTR NO. 12345, 01/06/18, Tacloban City
IBP NO. 54321, 01/04/18, Tacloban City
MCLE Comp. No. VIII-0007564, 01/02/18

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NOTICE OF HEARING

BRANCH CLERK OF COURT


Regional Trial Court
Tacloban City, Branch 7

ATTY. JUAN DE LA CRUZ


Counsel for Defendant
ABC Law Firm
Lopez, Jaena St., Tacloban City

Greetings:

Please take notice that the undersigned counsel will submit the
foregoing Motion for Execution to the Honorable Court on May 15, 2018 at
8:30 in the morning for its favorable consideration and approval.

ATTY. MAKI P. PERA


Counsel for Plaintiff
123, Real Street, Pasig City
Roll of Attorneys No. 98765
PTR NO. 12345, 01/06/18, Pasig City
IBP NO. 54321, 01/04/18, Pasig City
MCLE Comp. No. VIII-0007564, 01/02/18

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Copy Furnished:

ATTY. JUAN DE LA CRUZ


Counsel for Defendant
ABC Law Firm
Lopez, Jaena St., Tacloban City

Registry Mail No. Date:

EXPLANATION FOR FILING AND SERVICE BY REGISTERED MAIL

Due to lack of messengerial services to effect personal service, a copy


of the foregoing motion was sent to defendant's counsel through registered
mail.

ATTY. MAKI P. PERA


Counsel for Plaintiff
123, Real Street, Pasig City
Roll of Attorneys No. 98765
PTR NO. 12345, 01/06/18, Pasig City
IBP NO. 54321, 01/04/18, Pasig City
MCLE Comp. No. VIII-0007564, 01/02/18

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