Republic of the Philippines

9th Judicial Region

MUNICIPAL TRIAL COURT IN CITIES
Branch

SPS. AB & CD CIVIL CASE NO. ________

Plaintiff,
-for-

-versus-
UNLAWFUL DETAINER FORCIBLE
XYZ ENTRY
Defendants.
X ---------------------------------------------------- X

MOTION FOR THE ISSUANCE OF A WRIT OF

DEMOLITION

COMES NOW, Plaintiffs, through the undersigned counsel, and unto this
Honorable Court most respectfully state:

1. That on March 8, 2011, the undersigned counsel received a copy of the

Sheriffs Return dated February 2, 2011 stating among others that Defendants
were served with a copy of the Writ of Execution but such Writ was unsatisfied
and that Defendants are still occupying the premises and refused to vacate;

2. That due to the consistent refusal of Defendants to vacate the premises

despite the finality of the case and the issuance of the Writ of Execution, Plaintiffs
were unduly prejudiced of their right to possess the subject property for more than
ten (10) years;

3. That in view hereof, it is now necessary for the Honorable Court to issue a
Writ of Demolition ordering the demolition of the existing improvements therein
introduced by the Defendants to fully restore possession of the subject property
unto Plaintiffs.
 PRAY E R
WHEREFORE, premises considered, it is respectfully prayed of this
Honorable Court to issue a Writ of Demolition, to demolish the existing
improvements therein introduced by the defendants to fully restore possession
unto plaintiffs.

Other reliefs as are just and equitable under the circumstances are likewise
prayed for in the interest of justice.

Respectfully Submitted.

NOTICE

THE CLERK OF COURT

MTCC

G R E E T I N G S:

Please submit the foregoing Motion for the consideration and approval of the
Honorable Court immediately upon receipt hereof sans oral argument.