Republic of the Philippines

REGIONAL TRIAL COURT

6th Judicial Region
Branch 62
Bacolod City

JOSELITO PALMTRE, CIVIL CASE No. 16-0823-2413

Plaintiff,

FOR: Collection of a sum of money

- versus and damages

HAKILIN ADRINALINE,
Defendant.
x- - - - - - - - - - - - - -- - - - x

MOTION FOR APPROVAL OF

COMPROMISE AGREEMENT

The parties, Plaintiff Joselito Palmtre and Defendant Hakilin

Adrinaline, with the assistance of the undersigned counsels, unto the
Honorable Regional Trial Court Judge, most respectfully manifest and aver,
to wit:

1. In the interest of peace between the parties to this case, Respondent and
Complainant agree to amicably settle the same;

2. The parties entered into a Compromise Agreement which is attached hereto;

3. The parties agree that the approval of this agreement by the Court shall put
an end to this litigation, except for purposes of execution in case of default.

PRAYER

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 PREMISES CONSIDERED, the parties respectfully pray that the
court approve this agreement and render judgment on the basis thereof.

Other relief and remedies, just and proper under the premises are
likewise most respectfully prayed for.

Most respectfully submitted this 07 January 2017 in Bacolod City,

Philippines.

For the Complainant: For the Defendant:

MR. JOSELITO PALMTRE MS. HAKILIN ADRINALINE

Assisted by: Assisted by:

ATTY. PAT LUI A. HACUB ATTY. REXBUKS V. MELGAR

NOTICE

THE CLERK OF THE HONORABLE REGIONAL TRIAL COURT

JUDGE:

Greetings! Kindly submit the foregoing Motion to Dismiss for the kind
action and resolution of the Honorable Regional Trial Court Judge
immediately upon receipt hereof, without further need of oral arguments or
presence of counsel. Thank you.

PAT LUI A. HACUB REXBUKS V. MELGAR

COMPROMISE AGREEMENT

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 This Agreement executed this 23rd day of December, 2016 at Bacolod
City, by and between:

JOSELITO PALMTRE, Filipino, of legal age with address at Door No.

13, Magbayad Road, 16th Street, Bacolod City, represented herein by Atty.
Pat Lui A. Hacub (hereinafter referred to as the plaintiff).

-and-

HAKILIN ADRINALINE, Filipino, of legal age with address at Door

No. 23, Barangay Magutang, Bacolod City, represented herein by Atty.
Rexbuks V. Melgar (hereinafter referred to as the defendant).

WITNESSETH: That -

WHEREAS, the plaintiff PALMTRE and defendant ADRINALINE are

business partners.

WHEREAS, the plaintiff PALMTRE instituted the present action for

collection of a sum of money with damages.

WHEREAS, the parties desire to buy peace and wish to avoid a

protracted litigation in this case.

NOW THEREFORE, in consideration of the foregoing and the further

covenants hereinafter set forth, the parties agree as follows:

1. Plaintiff PALMTRE shall be paid the sum of THREE HUNDRED

THOUSAND PESOS (P300,000.00) in accordance with the following
schedule:

a. Initial payment ONE HUNDRED THOUSAND PESOS

(P100,000.00) shall be paid to the plaintiff PALMTRE by defendant
ADRINALINE upon the signing and due execution of this Compromise
Agreement, Provided, however, that the initial payment by defendant
ADRINALINE shall be delivered into the custody and possession of a third
party, Atty. Maria Mercedes, who shall act as escrow-trustee of the parties
and who shall only deliver the said initial payment to the plaintiff through
plaintiffs counsel upon the filing in Court of this Compromise Agreement.

b. The balance of TWO HUNDRED THOUSAND PESOS (P200,000.00)

shall be paid by defendant Adrinaline as follows:

Second payment - ONE HUNDRED THOUSAND PESOS (P100,000.00)

within sixty (60) days after the date of the first payment.

Third payment - ONE HUNDRED THOUSAND PESOS (P100,000.00)

within thirty (30) days after the date of the second payment.

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 2. The initial payment by defendant ADRINALINE shall be made in
cash. The two payments on the balance shall be covered by post-dated
checks drawn by defendant ADRINALINE as payable to ATTY. PAT LUI A.
HACUB who shall hold and account for said payments in trust for plaintiff
PALMTRE.

3. This Compromise Agreement shall not affect nor prejudice any case or
cases between the parties not specifically referred to herein.

4. Upon delivery of the initial payment made by defendant

ADRINALINE and delivered to the escrow-trustee of the parties, the parties
shall seek Court approval of this Compromise Agreement and the dismissal
of the case filed therein.

5. The signatories to this Agreement hereby represent and warrant that

they are duly authorized to execute this Agreement.

6. The parties or their assigns hereby waive, renounce and forever

quitclaim all their respective claims and counterclaims subject of the instant
action as well as those that may arise therefrom, in connection therewith or
in relation thereto.

7. The foregoing covenants are not contrary to law, morals, or public

policy and the parties bind themselves to comply strictly with their
undertakings.

IN WITNESS WHEREOF, parties herein affixed their signatures on

the date and place above written.

________________________ ______________________
Plaintiff Defendant

Signed in the presence of:

________________________
______________________