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    Motion For Writ of Execution

    Uploaded by

    Joel A. Ybañez
    This document is a petition for issuance of a writ of execution. It summarizes that a judgment was rendered in favor of the appellant on February 15, 2021. The judgment was released on February 23, 2021 and received by the appellant on October 28, 2022. It is requesting that a writ of execution be issued for the judgment as the defendant has not filed any appeals and the decision is now final and executory. Notice is also being provided that the motion for execution will be submitted on November 15, 2022.

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    Motion For Writ of Execution

    Uploaded by

    Joel A. Ybañez
    20 views3 pages
    This document is a petition for issuance of a writ of execution. It summarizes that a judgment was rendered in favor of the appellant on February 15, 2021. The judgment was released on February 23, 2021 and received by the appellant on October 28, 2022. It is requesting that a writ of execution be issued for the judgment as the defendant has not filed any appeals and the decision is now final and executory. Notice is also being provided that the motion for execution will be submitted on November 15, 2022.

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    Motion for Writ of Execution

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    This document is a petition for issuance of a writ of execution. It summarizes that a judgment was rendered in favor of the appellant on February 15, 2021. The judgment was released on February 23, 2021 and received by the appellant on October 28, 2022. It is requesting that a writ of execution be issued for the judgment as the defendant has not filed any appeals and the decision is now final and executory. Notice is also being provided that the motion for execution will be submitted on November 15, 2022.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    20 views3 pages

    Motion For Writ of Execution

    Uploaded by

    Joel A. Ybañez
    This document is a petition for issuance of a writ of execution. It summarizes that a judgment was rendered in favor of the appellant on February 15, 2021. The judgment was released on February 23, 2021 and received by the appellant on October 28, 2022. It is requesting that a writ of execution be issued for the judgment as the defendant has not filed any appeals and the decision is now final and executory. Notice is also being provided that the motion for execution will be submitted on November 15, 2022.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 3

    Republic of the Philippines

    Department of Environment and Natural Resources


    OFFICE OF THE SECRETARY
    And Office of the Undersecretary
    Legal, Administration, Human Resources, and Legislative Affairs
    Visayas Avenue, Dilliman, Quezon City
    -ooOoo-

    BENEDICTO BIHAG (Deceased), CRIM CASE NO. 21-7369


    REP. BY OCTAVIO ACENAS TO 21-7372 (4 COUNTS)
    Appellant
    -For -
    ,
    - versus - ESTAFA

    IGMEDIO R. COSEP, SR.


    (Deceased),
    REP. BY HIS HEIRS, FRANCISCO
    SIMO AND PRIMA YNOT,
    Appellee,

    BENJAMIN TUBILID, ET AL.,


    Intervenors.
    x-------------------------------------------x
    PETITION FOR ISSUANCE OF
    WRIT OF EXECUTION

    COMES NOW, the Appellant, through undersigned counsel and to this


    Honorable Office respectfully alleged:

    1. That judgment was rendered by the Honorable Secretary through the


    Office of the Undersecretary for Legal, Administration, Human
    Resources,
    and Legislative Affairs in favor of the Appellant on February 15, 2021;

    2. That said judgment was release from the Office of the DENR Secretary
    on February 23, 2021 as shown in the markings on a copy of the
    judgment;

    3. That said judgment was duly actually received by the Appellant on the
    28th day of October, 2022 as shown in the registry return card;

    4. 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 Office for a writ of execution of said judgment.
    Polomolok, South Cotabato, Philippines.

    November 8, 2022.

    ATTY. JOEL A. YBAÑEZ


    Counsel for the Appellant
    Attorney’s Roll No. 80124
    IBP No. 213208 – 5/19/2022 – CEBU
    PTR No. 2714065 – 9/13/2022 – Koronadal City
    TIN: 129-155-737
    MCLE Compliance: Provisionally Exempted until April 14, 2025

    Address:

    YBAÑEZ TAGALOGUIN CATAYUC


    & CATOLICO LAW OFFICES
    Units 2-4 3rd floor CSA Bldg.,
    Purok Pag-asa, Barangay Magsaysay,
    National Highway (Beside Shell Station),
    Polomolok, South Cotabato
    Mobile No. 0921-629-9918
    Email Address: [email protected]

    NOTICE OF HEARING

    Atty. Edward James A. Dy Buco


    Mosquera & Dy Buco Law Offices
    Counsel for the Appellee
    034 Dr. J. Crisologo St.
    9500 General Santos City

    Atty. Abdul F. Sarip Macmod


    Counsel for the Intervenors
    168 P. Acharon Boulevard
    General Santos City

    Francisco Simo
    Prima Ynot
    Representatives of Igmedio Cosep, Sr. (Deceased)
    Silway 8, Polomolok, South Cotabato

    Greetings!
    Please take notice that the undersigned counsel will submit the foregoing
    Motion for Execution to the Honorable Office on November 15, 2022 at 8:30
    in the morning for its favorable consideration and approval.

    Copy furnished by registered mail:

    DISTRICT LAND OFFICE XI - 3


    Koronadal, South Cotabato

    CENR Officer of CENR Office XI-4B


    General Santos City

    Benjamin Tubilid, et al.,


    Silway 8, Polomolok, South Cotabato

    The Regional Executive Director


    DENR – Region XI
    Km. 7, Lanang, Davao City

    The Regional Executive Director


    DENR – Region XII
    Dona Aurora Quezon Street
    Koronadal City, South Cotabato

    The Director
    Land Management Bureau
    880 F.R. Estuar Building, Quezon City

    The Assistant Secretary for Legal Affairs

    EXPLANATION

    Due to lack of messengerial services to effect personal service, a copy of the


    foregoing motion was sent through registered mail.

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