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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


SIXTH JUDICAL REGION
ILOILO CITY
BRANCH 30

IN THE MATTER OF THE


PETITION TO APPROVE
THE WILL OF
JUAN B. ANTONIO SR., S.P. NO. 1234
FOR: PROBATE OF WILL

JUAN A. ANTONIO JR.,


Petitioner.
x----------------------------------------x

MOTION TO FILE A CLAIM AGAINST THE ESTATE OF A


DECEASED PERSON

COMES NOW, the undersigned counsel for the claimant and unto
this Honorable Court, most respectfully manifests:

1. That claimant, CASSIE J. CONSTANTINO, is a Filipino citizen, of


legal age and a resident of Brgy. Buntatala, Jaro, Iloilo City;

2. That on January 5, 2015, claimant received a notice of the death of


Juan B. Antonio Sr. on July 1, 2014 and that a petition was filed
before this Honorable Court for the probate of his will on November
20, 2014;

3. That prior to his death, on October 20, 2013 deceased contracted a


loan of Three Hundred Thousand (PHP 300,000.00) with claimant as
evidenced by the promissory note signed by the latter herein attached
as Annex A;

4. That the said loan has become due and demandable last October 20,
2014 and the same has not yet been paid by the deceased;

5. That claimant hereby files this motion unto this Honorable Court in
compliance with Rule 86 of the Rules of Court.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed to
this Honorable Court that the foregoing claim against the estate of Carlisle
L. Kulin be approved and that the executor of the said estate be ordered to
pay claimant, Cassie J. Constantino, the amount of Three Hundred
Thousand Pesos (Php 300,000.00).

Iloilo City, Philippines, January 20, 2015.

ATTY. LAURENCE SUSAN P. ORTIZ


Counsel for the Claimant
Commission Serial. No. 1989
Valid until December 31, 2015
Ortiz, Law Office, Jaena St., Jaro, Iloilo City
Roll of Attorney No. 44661
PTR No. 22334, Iloilo City, January 17, 2014
IBP No. 44556, Iloilo City, January 10, 2014
MCLE Compliance No. VI-010489

THE CLERK OF COURT


Regional Trial Court, Branch 30
Sixth Judicial Region
Iloilo City

Greetings:

Kindly submit the foregoing Motion for leave of court to sell real
property under the administration of Ma. Annie B. Muyco, administrator of
the the estate of Juan B. Antonio Sr., to the honorable Presiding Judge
immediately upon receipt hereof for the resolution of the same, sans oral
argument.

ATTY. LAURENCE SUSAN P. ORTIZ


Counsel for the Petitioner
Commission Serial. No. 1989
Valid until December 31, 2015
Ortiz Law Office, Jaena St., Jaro, Iloilo City
Roll of Attorney No. 44661
PTR No. 22334, Iloilo City, January 17, 2014
IBP No. 44556, Iloilo City, January 10, 2014
MCLE Compliance No. VI-010489

Copy furnished through personal service:

ATTY. DAVE ROBERT CAPADA


Counsel for the heirs of Juan B. Antonio Sr.
Gerochi Law Office, Jereos St., La Paz, Iloilo City

Received by: Date:

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