REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL REGION

REGIONAL TRIAL COURT
LAS PIÑAS CITY
Branch 123

Aderis de la Cruz
Plaintiff, Civil Case No. 123456
For:
- versus-

Julius Mila
Defendant,

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MOTION FOR DEFICIENCY JUDGMENT

PLAINTIFF, respectfully avers that:

1. On March 2, 2015, pursuant to the writ of execution dated February

15, 2015, issued by this Honorable Court, the sheriff of RTC Las Pinas,
Branch 20 sold at public auction the property of the defendant to satisfy the
latter's obligation in favor of the plaintiff in the amount of P450,000.00;

2. After the auction sale of the defendant's real property on March 2,

2015, only the amount of P200,000.00 was realized. The proceeds of such
sale was delivered to the plaintiff less the expenses and cost of the auction
which amounted only to P150,000.00;

3. Since the total amount due from the defendant is P450,000.00, there
remains an unsatisfied balance of P300,000.00which should be paid to the
plaintiff to pay all obligations of the defendant under the judgment.

WHEREFORE, plaintiff prays that deficiency judgment be rendered

in favor of the plaintiff and against the defendant in the amount of

1
P300,000.00 and that the corresponding writ of execution issued forthwith.

Las Pinas City, April 30, 2015.

Atty. Amado P. Aquino III

Counsel
Roll No. 63140
IBP No. _______
PTR No. _______
Unit 2108, Jollibee Plaza,
Ortigas, Pasig City
MCLE Compliance No.
Until December 31, 2015

(Notice of Hearing)
(Copy Furnished)
(Proof of Service)