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Motion To Withdraw Funds

This document is a motion filed in a regional trial court in Cebu City, Philippines requesting permission to withdraw funds from a bank account. It summarizes that the plaintiff and defendants agreed to a compromise settling a civil case for 1.24 million pesos, with an initial deposit of 600,000 pesos to be made by the plaintiff. The motion asks the court to approve allowing the defendants to individually withdraw the deposited funds according to the terms of the compromise agreement.

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Tenshi Fukui
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121 views2 pages

Motion To Withdraw Funds

This document is a motion filed in a regional trial court in Cebu City, Philippines requesting permission to withdraw funds from a bank account. It summarizes that the plaintiff and defendants agreed to a compromise settling a civil case for 1.24 million pesos, with an initial deposit of 600,000 pesos to be made by the plaintiff. The motion asks the court to approve allowing the defendants to individually withdraw the deposited funds according to the terms of the compromise agreement.

Uploaded by

Tenshi Fukui
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


7th Judicial Region
Branch_____
Cebu City

NATIONAL GRID CORPORATION


OF THE PHILIPPINES
Plaintiff,
Civil Case No.
-versus-

MARIA NINFA Q. ESCARIO,


JEMELA ANNE ESCARIO-GOMEZ,
MARIO EDWARD ESCARIO II and,
BERYL ANNE ESCARIO
Defendants.
x- - - - - - - - - - - - - - -x

MOTION TO WITHDRAW FUNDS

COMES NOW, the undersigned defendants, unto this Honorable Court most
respectfully state:

1. That the above plaintiff and undersigned defendants have approved and
mutually agreed on the terms of the Compromise Agreement dated 7
November 2014 (herewith attached as Annex “A”);
2. That said Compromise Agreement was signed by all the defendants and the
Plaintiff’s authorized representative;
3. That said Compromise Agreement was filed and submitted before this
Honorable Court on _______;
4. That the terms of said Agreement, particularly on paragraph x, required the
Plaintiff to deposit the amount of SIX HUNDRED THOUSAND PESOS
(P600,000) with the Land Bank of the Philippines.
5. That said amount represents the initial deposit to be made by the Plaintiff and
forms part of the agreed compensation of ONE MILLION TWO FORTY
THOUSAND EIGHT HUNDRED PESOS (P1,240,800) in exchange for
herein defendants’ affected property;
6. That in pursuance of the provisions of the agreed COMPROMISE
AGREEMENT, herein defendants voluntarily accept said initial deposit and
are willing to open their respective bank accounts with the Land Bank of the
Philippines;
7. That herein DEFENDANTS have all agreed to enforce the terms of the
COMPROMISE AGREEMENT and enforce it to fruition;

WHEREFORE, in the light of the foregoing, it is most respectfully prayed of


this Honorable Court to approve this motion for withdrawal of funds deposited by
herein Plaintiff as its initial deposit and issue an order allowing herein
DEFENDANTS to be able to individually withdraw the funds deposited under their
names.

Cebu City, Philippines. ________________


Atty.___________

The Branch Clerk of Court


RTC Branch
Cebu City

Greetings:

Kindly submit the foregoing motion for reconsideration and approval of the
Honorable Court immediately upon receipt hereof sans oral argument.

Atty. ________________

CERTIFICATION OF SERVICE

Pursuant to Section 11, Rule 13 of the 1997 New Rules of Civil Procedure, it is
hereby certified that a copy of this Motion has been furnished to Atty. ___________,
Asst. City Pros. _______________and this Court via personal deliveries and
registered mail respectively, personal service to all being impracticable due to
distance.

Atty. ________________

Copy furnished:

Asst. City Prosecutor

Atty. _________
Address__________

The Branch Clerk of Court

Greetings:

Kindly submit the foregoing motion for reconsideration and approval of the
Honorable curt immediately upon receipt hereto sans oral argument.

Atty. _______

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