Republic of the Philippines

National Capital Judicial Region

METROPOLITAN TRIAL COURT
City of Parañaque
Branch 78

PEOPLE OF THE PHILIPPINES, Crim. Case No. 17-1567

Complainant, For : Violation of B.P. 22

-versus-

ANTHONY VLADIMIR O.
PELAYO,
Accused.
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MOTION FOR ISSUANCE OF WRIT OF EXECUTION

COMES NOW Movant, unto this Honorable Court most

respectfully submits this Motion for Issuance of Writ of Execution and
in support thereof most respectfully avers:

1. That this is a case for violation of B.P. 22, filed by complainant

with this Honorable Court on July 13, 2017. Whereas after
arraignment wherein accused pleaded not guilty, the case was
directed to undergo mediation at the Philippine Mediation
Center, Parañaque City;

2. That at the mediation, parties agreed to enter into a compromise

agreement. In the compromise agreement, the accused shall pay
five thousand pesos every 15 and 30th of the month until fully
paid. A copy of the said compromise agreement is attached as
Annex “1”;

3. However, accused has failed to full pay his remaining balance of

Twelve Thousand Eight Hundred and Seventy-Five Pesos
 (P12,875.00) and has not responded to repeated demands for his
full payment of the compromise agreement;

4. That for failure of the accused to pay, I move that a writ of

execution be issued based on the compromise agreement and
that the criminal case for B.P. 22 to continue.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed unto this Honorable Court that a Writ of Execution be issued
directing the accused to pay P12, 875.00 with legal interest; and to pay
attorney’s fees of P40,000.00, costs of suit, and continuation of the
criminal case for B.P. 22 against the accused.

OTHER RELIEFS just and equitable are likewise prayed for.

September 26, 2018 18, Parañaque City, Philippines.

MARYANNE UY HSU
Complainant

NOTICE OF HEARING
and COPY FURNISHED

Copy Furnished:

BRANCH CLERK OF COURT

MTC Branch 78
Paranaque City

ATTY. SARAH CHAVEZ

Counsel for Accused
Public Attorney’s Office (PAO)
Paranaque City
ANTHONY VLADIMIR O. PELAYO
Accused
163 Armstrong St.,
Moonwalk Village
Phase 2, Paranaque City

GREETINGS

Please take notice that the undersigned shall submit the

foregoing motion for the kind consideration and approval of this
Honorable Court on __________________ in the _________ as
necessary if motion need be heard.

MARYANNE UY HSU

MANIFESTATION

The undersigned movant informs the Honorable Court that copy

of the foregoing motion was served upon the above-named counsel by
registered mail due to distance and time constraints, and
unavailability of messenger to effect personal service.

MARYANNE UY HSU