Republic of the Philippines

First Judicial Region

MUNICIPAL TRIAL COURT
Branch 3
Baguio City

GUSTAVO L. FRING,
Plaintiff,

- versus - Civil Case No. 23242

For: Collection of Sum of Money
SAUL S. GOODMAN,
Defendant.
x-----------------------------------------------x

MOTION FOR EXECUTION OF JUDGMENT

COMES NOW, the Plaintiff through undersigned counsel and to

this Honorable Court respectfully alleged:

1. That judgment was rendered by this Honorable Court in favor of the plaintiff on
April 15, 2017;

2. That said judgment was duly received by the defendant on April 17, 2017 as shown
in the registry return card;

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

WHEREFORE, it is respectfully prayed that an order be issued by

this Honorable Court for a writ of execution of said judgment.

Baguio City, Philippines. May 19, 2017.

ATTY. JULIUS R. BALAJADIA

Counsel for Plaintiff
 NOTICE OF HEARING

THE BRANCH CLERK OF COURT

MTC - Branch 3
Baguio City

ATTY. CHUCK S. GOODMAN

Counsel for the Defendant
323 Abanao Street, Baguio City

Greetings!

Please take notice that the undersigned counsel will submit the foregoing Motion
for Execution to the Honorable Court on May 22, 2017 at 9:00 in the morning for its
favorable consideration and approval.

ATTY. JULIUS R. BALAJADIA

Counsel for Plaintiff

Copy furnished by registered mail:

ATTY. CHUCK S. GOODMAN

Counsel for the Defendant
323 Abanao Street, Baguio 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.

ATTY. JULIUS R. BALAJADIA

Counsel for Plaintiff