Republic of the Philippines
MUNICIPAL TRIAL COURTS IN CITIES
Second Judicial Region
Branch 01
Tuguegarao City, Cagayan
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Crim. Cases: 31336 – 37
-versus- For: Serious Physical
Injuries
DOMINADOR V. DOMINGO, JR,
JOASH VICTOR C. DOMINGO,
ALBERTO B. DOMINGO II,
ALBERTO B. DOMINGO III,
CHRISTOPHER B. VALLEJOS,
AND VINCENT MARCO S.
DOMINGO,
Accused.
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MOTION FOR EXECUTION
Private Complainant by himself, unto this most Honorable Court,
respectfully state:
1. On 30 July 2020, the Honorable Court promulgated its Joint
Decision which convicted two of the accused in the above-stated cases.
2. The said Joint Decision awarded the following amounts to
Avelino Q. Sibbaluca, Sr:
In Criminal Case No. 31336
(i). PhP 30,000.00 as moral damages;
(ii). PhP 15,000.00 as exemplary damages;
(iii). PhP 10,000.00 as attorney’s fees;
In Criminal Case No. 31337
(i). PhP 5,000.00 as moral damages.
3. The judgment is already final and executory.
4. Thus, the undersigned private complainant now moves for the
execution of the civil liabilities of both accused.
Relief
WHEREFORE, it is respectfully prayed that a WRIT OF
EXECUTION be issued by this Honorable Court to enforce the civil aspect
of its judgment for the FULL PAYMENT of both accused’s obligations in
the total amount of PhP 60,000.00 to herein private complainant.
Other reliefs that are just and equitable are likewise prayed for.
Tuguegarao City, Cagayan, 14 November 2020.
by:
AVELINO Q. SIBBALUCA, SR.
Conforme:
CELERINO S. REYES
Prosecution Attorney
Trial Prosecutor MTCC Br.1
Request/Notice of Hearing/ /Copy Furnished to:
HON. BRANCH CLERK OF COURT
MTCC Branch 1, Tuguegarao City, Cagayan
ATTY. SANTOS M. BACULI,
Counsel for All Accused
Baculi and Baculi Law Offices,
Maharlikha Highway, Carig Sur,
Tuguegarao City, Cagayan
Greetings:
Kindly submit the foregoing motion for the consideration and approval of the Honorable Court on
November 20, 2020 at 1:30 p.m. or immediately upon your receipt hereof.
AVELINO SIBBALUCA, SR.