Republic of the Philippines

ND
2 MUNICIPAL CIRCUIT TRIAL COURT
ALABEL-MALUNGON
11th Judicial Region
Alabel, Sarangani Province

SPOUSES TERESITA & CIVIL CASE No. 17-197-A

PEDRO NEBRES,
Plaintiffs,

-versus- -for-

MACARIA NEBRES ALSA RECOVERY OF

AND EDEN BODEGAS, POSSESSION, DAMAGES
Defendants. AND ATTORNEY’S FEES
X---------------------------------------X

MOTION FOR THE ISSUANCE OF

WRIT OF EXECUTION

COMES NOW Plaintiffs, through counsel from the Public

Attorney’s Office and unto this Honorable Court most respectfully
submit this Motion for the Issuance of Writ of Execution and in
amplification thereof most respectfully aver:

1. That this is a case for Recovery of Possession, Damages and

Attorney’s Fees filed by Plaintiffs with this Honorable Court
wherein Judgment DATED December 19, 2019 was made in
favor of plaintiffs, the dispositive portion of which provides:

“WHEREFORE, premises considered, judgement is

hereby rendered in favor of plaintiffs Spouses Teresita and
Pedro Nebres.

ACCORDINGLY, defendants Macaria Nebres Alsa and

Eden Bodegas are ORDERED to immediately vacate the
subject Lot No. 77, a 600-square meter parcel of land located in
Dagohoy St., Purok 5 (Cogonal) Barangay Poblacion, Alabelm
Sarangani Province.

SPS. NEBRES vs ALSA AND BODEGAS//Civil Case No. 17-197-A//RECOVERY OF

POSSESSION, ETC.
MOTION FOR WRIT OF EXECUTION
Page 1 of 3
 SO ORDERED.”

2. That said judgment was duly received by the defendants

through their counsel on 02 January 2020;

3. That up to the present, the defendant had not filed any motion
for reconsideration or had appealed from said decision, thereby
rendering judgment final and executory.

4. Hence, it is proper and prayed that a writ of execution be

issued by this Honorable Court to protect the interest of the
plaintiffs and prevent unfairness and unjust enrichment on
defendants’ part.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed unto this Honorable Court that a Writ of Execution be issued
directing the defendants to vacate the subject property Lot No. 77, a
600-square meter parcel of land located in Dagohoy St., Purok 5
(Cogonal) Barangay Poblacion, Alabelm Sarangani Province and
turn-over the possession of the same to the plaintiffs.

Other reliefs just and equitable are likewise prayed for.

Alabel, Sarangani Province, 20 January 2020.

RESPECTFULLY SUBMITTED:

PUBLIC ATTORNEY’S OFFICE

Department of Justice
Sarangani District Office
Alabel, Sarangani Province

BY:

BAI ALEFHA HANNAH M. MUSA-ABUBACAR

Public Attorney II
Roll of Attorney No. 67366
MCLE Compliance No. VI-0009755
SPS. NEBRES vs ALSA AND BODEGAS//Civil Case No. 17-197-A//RECOVERY OF
POSSESSION, ETC.
MOTION FOR WRIT OF EXECUTION
Page 2 of 3
 IBP OR No. 098228-01/Jan/2019
Email Add: hannahalefha20@gmail.com
09090154295
PTR Exempt

NOTICE

THE CLERK OF COURT

MCTC Alabel-Malungon
Alabel, Sarangani Province

G r e e t i n g s:

Please submit the foregoing Motion for the Issuance Writ of

Execution for consideration and approval of the Honorable Court
immediately upon receipt hereof and set it for hearing on the date
most convenient to the Honarable Court.

ATTY. UMAR M. GENITA

Purok 4, Calina St.
Lagao, General Santos City

Please take notice that the undersigned counsel submits the

foregoing Motion for the Issuance Writ of Execution for the
consideration and approval of this Honorable Court.

BAI ALEFHA HANNAH M. MUSA-ABUBACAR

EXPLANATION

Service of the foregoing Motion for Writ of Execution was made

through registered mail due to distance, manpower and time
constraint.

BAI ALEFHA HANNAH M. MUSA-ABUBACAR

Copy furnished:
ATTY. UMAR M. GENITA
Purok 4, Calina St. Received by:
Lagao, General Santos City Date:

SPS. NEBRES vs ALSA AND BODEGAS//Civil Case No. 17-197-A//RECOVERY OF

POSSESSION, ETC.
MOTION FOR WRIT OF EXECUTION
Page 3 of 3