Republic of the Philippines

National Capital Judicial

Metropolitan Trial Court
Pasay City, Branch 45

Global Dominion Financing, Inc.

Plaintiff,

- versus - Civil Case No.M-PSY-19-01611-CV

MARCO BUNAGAN MABAZZA

and John Doe
Defendants.
x----------------------------------------x

JOINT MOTION TO APPROVE COMPROMISE AGREEMENT

COME NOW the parties, assisted by the undersigned

counsel, unto this Honorable Court most respectfully state
that:

1. On 13 June 2019, a complaint was filed before this

Honorable Court.

2. Plaintiff filed a Replevin Bond in compliance to

Section 2 Rule 60 of Rules of Court.

3. The parties herein desire to settle the above-captioned

case and without further litigation and to that end, are
therefore willing to enter into this Compromise
Agreement.

COMPROMISE AGREEMENT

4. In full settlement of plaintiff’s claim against

defendants, the parties agreed as follows:

a. Upon signing of this Agreement, the parties

shall jointly cause the approval of this Compromise
Agreement by this Honorable Court, who shall in
turn render judgment (with prejudice) based on the
terms and conditions stipulated herein;

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 b. That the total civil obligation of defendant to
plaintiff is in the amount of THREE HUNDRED
SEVENTY-FOUR THOUSAND EIGHT HUNDRED
FIFTY-TWO PESOS AND 65/100 (Php 374, 852.65)
including penalties and legal charges which shall be
paid as follows:

b.1. Upon execution of this agreement,

defendant paid to plaintiff the amount of Fifty-Two
Thousand Three Hundred Forty-Four Pesos and
65/100 (Php52, 344.65).

b.2. The remaining balance of Three Hundred

Thousand Pesos (340, 000.00) shall be paid in
Twenty (20) monthly installment in the amount
Seventeen Thousand Pesos (Php17, 000.00)
starting November 15, 2019 until June 15, 2021.

5. Failure of the defendant to pay any amount due will

give rise to the rights of the Plaintiff for issuance of
writ of execution for the physical delivery of the vehicle
subject matter of this case, with plate no. ACL4699 or
in the alternative, for defendant to pay plaintiff the
entire balance including legal interest of 12% per
annum from the time of default and attorney’s fees
equivalent to 25% of the total outstanding obligation.

6. The parties herein are executing this compromise

agreement upon considerations not contrary to law,
public policy and public morals with utmost good faith
to settle amicably the above-captioned case.

PRAYER

WHEREFORE based on the foregoing, the parties

respectfully pray that a judgment be issued ordering the
approval of the compromise agreement submitted before this
Honorable court.

Other remedies, just and equitable under the premises

are likewise prayed for.

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 __ October 2019. Ortigas Center, Pasig City for Pasay
City.

Ed M. Manzano Marco Bunagan Mabazza

Plaintiff’s Representative Defendant

ATTY. GERARDO A. SADSAD

Counsel for Plaintiff Global Dominion Financing Inc.
Unit 1604 16th floor Jollibee Plaza Condominium Emerald
Ave.
1605 Ortigas Center, Pasig City, Metro Manila
IBP No. 63999/ 1-7-19/ Pasig City
PTR No. 6413204/ 1-3-19/ Pasay City
Attorney’s Roll No. 52891
MCLE Compliance No. VI-0003120
August 22, 2017

ATTY. MA. VICTORIA C. SEVILLA

Counsel for Plaintiff Global Dominion Financing Inc.
Unit 1605 16th floor Jollibee Plaza Condominium Emerald
Ave.
1605 Ortigas Center, Pasig City, Metro Manila
IBP No. 016823; Manila IV; 3 October 2019
PTR No. 8011406; Manila; 28 December 2018
Roll No. 69912

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 MCLE No. VI-0016515
April 14, 2019

Notice of Hearing

To the Branch Clerk of Court:

MTC-Br. 45

Defendant Marco Bunagan Mabazza

Greetings!

Please submit the foregoing motion for the consideration and

approval of the Honorable Court on ____________, 2018 at
_____________________.

ATTY. GERARDO A. SADSAD

ATTY. MA. VICTORIA C. SEVILLA

Copy furnish by Personal Service:

__________________________
MARCO BUNAGAN MABAZZA
No. 245 Luna St., Centro Northwest,
Solana, Cagayan