Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Ninth Judicial Region
Branch 2
Zamboanga City
-oOoOo-

LUCIA VICENTE,
Plaintiff,

versus CIVIL CASE No. 7683

CAROLINA SACRO, NORMA GARINA, For

MICHAEL MATUTES, BOY JACINTO,
BRIGIDA TAYCO, and all other RECOVERY OF POSSESSION
occupants in the property covered by WITH DAMAGES
TCT No. 129-2016000707,
Defendants.
x-----------------------------------------x

MOTION FOR ISSUANCE OF WRIT OF EXECUTION

PLAINTIFF LUCIA VICENTE, through the undersigned counsel and
unto this Honorable Court respectfully submits this Motion for Issuance of
Writ of Execution and avers the following, to wit-

1. That on September 2, 2020, the Honorable Court rendered a

decision, the dispositive portion of the same reads-

“WHEREFORE, the Court renders JUDGMENT in favor of the

Plaintiff directing the defendants, their heirs, assigns, representatives
and/or any person acting for and in their behalves to:

a. Immediately vacate the subject properties, and to

demolish/dismantle all their houses and other structures on
the properties; should the defendants refuse to comply, the
plaintiff may demolish/dismantle them at the expense of
the defendants.

b. Pay reasonable rentals of the use and occupation of the

subject properties at Php 1,000.00 per month from July
2016 for each of the defendants; and

c. Pay Php 15,000 as Attorney’s fees.

SO ORDERED.”
 2. That on January 28, 2021, the Plaintiff, through the undersigned
counsel, received a copy of the Certificate of Finality of Judgment
stating among others that, xxx there being no motion for
reconsideration nor other modes of appeal availed by the
defendants, the DECISION dated September 2, 2020, of this Court, on
September 17, 2020, became FINAL and EXECUTORY;

3. Up to this date, Defendants have not complied with the Judgment

rendered by the Honorable Court.

WHEREFORE, premises considered, it is most respectfully prayed that

a Writ of Execution be issued to implement the judgment of this
Honorable Court dated September 2, 2020.

Such other equitable and just reliefs are likewise prayed for.

RESPECTFULLY SUBMITTED. 19 February 2021, City of Zamboanga,

Philippines.

DESIREE VON ENRIQUEZ-TORRES

Counsel for Plaintiff
Roll No. 67175; 05/24/17
IBP No. 120908; 12/16/2020; ZAMBASULTA
PTR No. 2173446; 01/05/2021; ZC
MCLE Compliance No. VI-0014584
until April 14, 2022
 NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Greetings!

Please take notice that undersigned counsel is submitting the

foregoing motion for the resolution of the Honorable Court without further
oral arguments.

Zamboanga City, 19 february, 2021.

Atty. Desiree Von Enriquez-Torres

COPY FURNISHED:

ATTY. RHEA DOLL B. GONZALO/ ATTY. JOHN PHILIP DELOTINA

Counsel for Defendants
Public Attorney’s Office
Hall of Justice, Zamboanga City