Request For Admission PDF
Request For Admission PDF
Request For Admission PDF
X ---------------------------------------------- X
1. All parties in the instant have already executed and are observing an
existing agreement regarding the division – i.e. allotment, management
and partition—of the corporation’s (i.e. Dulalia’s Inc.’s) assets.
2. The division of assets under said agreement were made per “family
branch” of Pablo Dulalia, Sr., with each child of Pablo Dulalia Sr.—
namely , Emilio Z. Dulalia, Lilia Dulalia Justiniani, Pablo Z. Dulalia, Jr.,
and Rafael Z. Dulalia—together with their respective heirs, being
considered as one “family branch”.
3. Under said agreement each family branch shall be entitle to all the
income, and shall be responsible for all the expenses— such as taxes,
expenses of operation, maintenance, and transfer/titling to the
particular family branch /heirs, etc.—pertaining to all the properties
which is always allocated to each branch respectiviely.
4. The division of the assets of Dulalia’s Inc. among the four (4) branches
(heirs of the four (4) children of Pablo Dulalia, Sr.) resulted in the
separate exercise of the rights of absolute ownership over specific
properties by each branches, which were all enumerated in the Request
2
5. The family branch / heirs of Pablo Z. Dulalia, Jr. presently owns not
only the properties listed in the Request for Admission (a copy is herein
attached as Annex “A”) submitted last October 24, 2018, but also the
following parcels of land and the improvements thereon:
a. Lot No. 3, Blk. 2541 TCT No. 72735 registered in the name of
Dulalia, Inc. : Main Theatre Bldg. in Quiapo, Manila
b. Lot No. 5-A covered by TCT No. 165547 registered in the name
of Dulalia’s Inc. : i.e., Landbank Bldg. on Roxas Blvd, Manila.
c. Lot 16, Blk. 23 covered by TCT No. (189333) 108821 registered
in the name of Dulalia’s Inc. .e., Baclaran Apartments in
Parañaque
RESPECTFULLY SUBMITTED.
CYBILL D. DIAZ
Counsel for Plaintiff
Teodosio, Daquilanea, Ventilacion
and Averia Law Offices
Javelosa Compd., Arguelles Ext.,
Locsin-Villalobos St., Jaro, Iloilo City
IBP NO. 068560-01/08/19
PTR NO. 6879289-12/3/19
Roll No. 70867
MCLE Date Complied: 11/ 29/2019
(Admitted to the bar: June 05, 2018)
Tel No. (033)3202977;(033)5092734
E-mail add: [email protected]
Copy furnished: