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Motion To Approve Compromise Agreement

This document is a motion filed in court requesting approval of a compromise agreement between Plaintiff ABC and Defendant CDE in an ejectment case. The key terms of the agreement are: 1) Defendant will pay an additional ₱1,000 monthly rent, totaling ₱4,000 per month, by providing 30 postdated checks covering the period until the end of the lease term in September 2019. 2) Defendant will self-regulate its business operations. 3) Plaintiff will assist Defendant in obtaining a separate water connection. Court approval of the agreement will end the litigation, except to enforce the terms in case of default.

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754 views3 pages

Motion To Approve Compromise Agreement

This document is a motion filed in court requesting approval of a compromise agreement between Plaintiff ABC and Defendant CDE in an ejectment case. The key terms of the agreement are: 1) Defendant will pay an additional ₱1,000 monthly rent, totaling ₱4,000 per month, by providing 30 postdated checks covering the period until the end of the lease term in September 2019. 2) Defendant will self-regulate its business operations. 3) Plaintiff will assist Defendant in obtaining a separate water connection. Court approval of the agreement will end the litigation, except to enforce the terms in case of default.

Uploaded by

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

Fourth Judicial Region


METROPOLITAN CIRCUIT TRIAL COURT

ABC, SCA No. 123456-7


Plaintiff,

-versus-
For: Ejectment
CDE,
Defendant.
x ------------------------x

MOTION FOR APPROVAL OF


COMPROMISE AGREEMENT

The Parties respectfully allege:

1. Plaintiff filed this case against Defendant for Ejectment.


2. The Parties have come to an amicable settlement and executed a
Compromise Agreement with the following terms and conditions, to wit:

“1. SECOND PARTY agreed to pay an additional rental fee in the


amount of ₱1,000.00/month starting April 2017, thus, making the
monthly rental fee for the use of the leased premises in the amount
of ₱4,000.00. Relative to this, the SECOND PARTY shall issue
postdated checks covering the period April 2017 until the end of the
term of the contract in September 2019, or a total of thirty (30)
postdated checks, to wit:

Date Amount Check No.


April 10, 2017 ₱4,000.00
May 10, 2017 ₱4,000.00
June 10, 2017 ₱4,000.00
July 10, 2017 ₱4,000.00
August 10, 2017 ₱4,000.00
September 10, 2017 ₱4,000.00
October 10, 2017 ₱4,000.00
November 10, 2017 ₱4,000.00
December 10, 2017 ₱4,000.00
January 10, 2018 ₱4,000.00
February 10, 2018 ₱4,000.00
March 10, 2018 ₱4,000.00
April 10, 2018 ₱4,000.00
May 10, 2018 ₱4,000.00
June 10, 2018 ₱4,000.00
July 10, 2018 ₱4,000.00
August 10, 2018 ₱4,000.00
September 10, 2018 ₱4,000.00
October 10, 2018 ₱4,000.00
November 10, 2018 ₱4,000.00
December 10, 2018 ₱4,000.00
January 10, 2019 ₱4,000.00
February 10, 2019 ₱4,000.00
March 10, 2019 ₱4,000.00
April 10, 2019 ₱4,000.00
May 10, 2019 ₱4,000.00
June 10, 2019 ₱4,000.00
July 10, 2019 ₱4,000.00
August 10, 2019 ₱4,000.00
September 10, 2019 ₱4,000.00

3. The SECOND PARTY shall self-regulate the operations of her


business, such as, reduction of volume of the videoke machine used,
time of operations (7:00PM to 3:00PM), proper disposal of
wastes/garbage and proper use of restroom facility by its
customers.

4. The FIRST PARTY, on the other hand, shall issue an authorization


and/or give her consent relative to the application of SECOND
PARTY to have her water meter and have her own source of water
supply.

5. The FIRST PARTY shall likewise remind her children, from time
to time, from interfering with the business of the SECOND PARTY.

6. This agreement shall not in any way be construed as an


admission on the part of any party of any fault, negligence or
liability, of whatever kind and nature, in connection with the
Pending Case.
7. The foregoing covenants are not contrary to law, morals, or
public policy and the parties bind themselves to comply strictly with
their undertakings.

8. In case of material breach of the terms and conditions of this


agreement, the innocent party is hereby authorized to apply for a
writ of execution in the Pending Case for the purpose of compelling
compliance with the terms and conditions of this agreement.”

3. The Parties agree that the approval of this agreement by the Court
shall put an end to this litigation, except for purposes of execution in case of default

WHEREFORE, premises considered, the parties respectfully pray that the


Court approve this agreement and render judgment on the basis thereof.

____________________________

ABC CDE
Plaintiff Defendant

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