REPUBLIC OF THE PHILIPPINES

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Branch xx, xx City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Criminal Case Nos.: xxxxx

xxxx,
Defendant.
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MOTION FOR EXECUTION

COMES NOW, the private complainant through undersigned

counsel and to this Honorable Court respectfully alleged:

1. On 17 December 2019, the private complainant and herein defendant

entered into a compromise agreement, duly approved by this
Honorable Court on 3 August 2020, upon which a Compromise
Judgment (“Judgment”) was rendered, which states among others:

1.1. That the defendant shall pay the private complainant the
settlement amount of Nine Million Pesos (Php 9,000,000.00) in
accordance with the schedule of payment as indicated in the
Judgment.

1.2. That should the defendant fails to comply with the said
agreement, he shall be given a non-extendible five (5) days
grace period to settle the installment amount.

1.3. That in case of non-payment after the lapse of the grace

period, the entire balance of the settlement amount shall be
immediately due and demandable without further demand or
notice.

2. Pursuant to the said Judgment, the defendant issued the following

Bank of the Philippine Islands (“BPI”) checks No. xxxxxxx dated
xxxxxxxxxxxxxx1, all of which were dishonored for being drawn
against insufficient funds.

3. Upon receipt of the Demand Letter dated 28 May 2021, herein

defendant still was not able to make good the value of the dishonored
 Checks totaling to Three Million Twenty Thousand Pesos (Php
3,020,000.00).

4. By virtue of the Compromise Judgment rendered by this Honorable

Court, the private complainant is hereby entitled, among others, to
apply for a Writ of Execution on the outstanding obligation totaling to
Nine Million Pesos (Php9,000,000).

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed for of

this Honorable Court that:

1. A writ of execution be issued to implement the provisions of the

Compromise Judgment dated 3 August 2020, to effect the full
payment of the outstanding settlement amount of Nine Million
Pesos (Php9,000,000).

Private complainant prays for other reliefs and remedies just and
equitable under the premises.

xxxxx, July 19, 2021.