Script For Initial Hearing Jurisdictional Facts

JURISDICTIONAL FACTS
1. On January 20, 2017, Mario Gonzales died whose estate is the subject of this petition for
letters of administration. The fact of his death is evidenced by his death certificate which
we would like to be marked as our “Exhibit A” (B)
2. At the time of the death of the deceased, he was last residing at 148 Singson Village,
Guadalupe, Cebu City, which is well within the jurisdiction of the Honorable Court. This
fact of residence is evidenced by the following: (C)
1) The latest Driver’s License I.D. of the deceased which we would like to be
marked as our “Exhibit B-1”
2) The latest BIR TIN I.D. of the deceased which we would like to be marked as
our “Exhibit B-2”
3) The latest internet service bill of the deceased which we would like to be
marked as our “Exhibit B-3”
3. So far as known to the Petitioner, the names, ages, and residences of the surviving heirs
of the deceased are as follows:
1) Luigi F. Gonzales, 28 years of age, and with residence address at Unit 84, City
Suites Tower, F. Ramos St., Cebu City; and
2) Judy F. Gonzales, 26 years of age, and with residence address at 107 Madrid
St., Villa del Rio Subdivision, Bacayan, Cebu City.
The named surviving heirs are the children of the deceased with his former spouse, Emily
L. Fernandez, whose marriage was judicially declared void on September 27 2000.
4. To the best of Petitioner’s knowledge, the deceased left an estate with a probable gross
value of at least 50 000 000, such amount is well within the jurisdiction of the Honorable
Court, consisting of the following: (D)
1) Residential house with an assessed value of 22, 081, 530 as evidenced by an
assessment report which we would like to be marked as our “Exhibit C-1”
2) Commercial building with an assessed value of 12, 081, 530 as evidenced by
an assessment report which we would like to be marked as our “Exhibit C-2”
3) Parcel of agricultural land with an assessed value of 1 000 000 as evidenced
by an assessment report which we would like to be marked as our “Exhibit C-
3”
4) Bank accounts amounting to 9 725 475.90 evidenced by a certificate of bank
deposit which we would like to be marked as our “Exhibit C-4”
5) Shares of stocks with a market value of 5 000 000 evidenced by a certificate
of stock which we would like to be marked as our “Exhibit C-5”
6) Unpaid credit amounting to 5 000 000 evidenced by a promissory note which
we would like to be marked as our “Exhibit C-6”
7) Motor vehicles which are the following:
1) Mitsubishi Pajero Sport with an assessed value of 330 000 as
evidenced by an assessment report which we would like to be marked
as our “Exhibit C-7”
2) Toyota Corolla with an assessed value of 110 000 as evidenced by an
assessment report which we would like to be marked as our “Exhibit
C-8”
5. Petitioner is aware of pending debts of the deceased considering that Petitioner is a

confidant of the deceased in his businesses. So far as known to the Petitioner, the names
of the creditors and respective amounts of the debts are the following: (E)
1) Bank of the Philippine Islands (BPI), 3 600 800 evidenced by the latest
demand letter which we would like to be marked as our “Exhibit D-1”
2) Metropolitan Bank and Trust Company (Metrobank), 3 150 000 evidenced by
the latest demand letter which we would like to be marked as our “Exhibit D-
2”
3) JGC Financing Company, Inc., 1 800 000 evidenced by the latest demand
letter which we would like to be marked as our “Exhibit D-3”
6. The Honorable Court issued an Order dated February 14, 2017 to cause publication of
such Order and furnish the heirs and creditors a copy each of the petition. (F)
7. In full compliance of such Order, the Petitioner had caused its publication once a week
for 3 consecutive weeks in a newspaper of general circulation in the cities and province
of Cebu as evidenced by an affidavit executed by the news editor which we would like to
be marked as our “Exhibit E” (G)
8. Likewise, in full compliance of such Order, copies of the petition were furnished each to
the heirs and creditors 10 days before the hearing as evidenced by the sheriff’s return
which we would like to be marked as our “Exhibit F” (H)
9. The Petitioner, Sophia H. Medina, is qualified, competent, and willing to be appointed as

regular administrator of the intestate of the deceased because she possesses all the
qualifications and none of the disqualifications. Petitioner is also ready, willing, and able
to give a bond in such sum and under such conditions as the Honorable Court may fix
and impose.
10. Therefore, having duly established the jurisdictional facts of our petition for issuance of
letters of administration pursuant to Rule 79 of the Rules of Court, this humble
representation prays to the Honorable Court to take cognizance of our petition in order to
protect the integrity of the estate of the deceased.

Script For Initial Hearing Jurisdictional Facts

Uploaded by

Copyright:

Available Formats

Script For Initial Hearing Jurisdictional Facts

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Script For Initial Hearing Jurisdictional Facts

Uploaded by

Copyright:

Available Formats

JURISDICTIONAL FACTS

5. Petitioner is aware of pending debts of the deceased considering that Petitioner is a

9. The Petitioner, Sophia H. Medina, is qualified, competent, and willing to be appointed as

You might also like