Professional Documents
Culture Documents
Motion For Execution Pending Appeal
Motion For Execution Pending Appeal
Pedro Sanchez
Plaintiff,
Juan Santiago,
Defendant.
x-------------------------------------------x
COME NOW THE PLAINTIFFS, through the undersigned counsel and before this Honorable
Court, they most respectfully allege that:
1. That a decision has been rendered in this case on November 20, 2005 in favor of the
Plaintiffs and against the defendant.
2. That the period for appeal for the defendant thru his counsel has already perfected or
within the period given or allowed under the rules on summary procedure, but
unfortunately the defendant himself failed to pay or deposit the required rentals or
supersedeas bond and under Sec. 19 Rule 70 of the Revised Rules of Summary
Procesure, as reiterated in the numerous decision of the Supreme Court, to wit:
3. And based on the records of the Court the defendant failed to deposit the sufficient
supersedeas bond or rentals awarded by the lower court in his decision on November 20,
2005, hence the plaintiffs have no recourse but to inform and persuade the court to grant
the order for the immediate execution of the decision of the Municipal Trial Court.
ATTY. Yud Po
Counsel for Plaintiff
NOTICE OF HEARING
ATTY. Wey Yu
Counsel for the Defendant
5789 Zamora Street, Pasay City
Greetings!
Please take notice that the undersigned counsel will submit the foregoing Motion for
Execution to the Honorable Court on May 25, 2023 at 8:30 in the morning for its favorable
consideration and approval.
Copy furnished by registered mail:
ATTY. ABC
Counsel for the Defendant
1234 Zamora Street, Pasay City
EXPLANATION
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.