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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
6TH Judicial Region
Branch 39
Iloilo City

VIRGILIO M. DULALIA, ET.AL,

Petitioners,
SCC Case No. 17-075
-versus- For: Liquidation and
Distribution of Assets
of a Dissolved Corporation
HEIRS OF PABLO DULALIA SR.,
ET.AL,
Respondents.

X ---------------------------------------------- X

REQUEST FOR ADMISSION

COME NOW the Petitioner Virgilio M. Dulalia, for himself and in

representation of the other heirs of Pablo Z. Dulalia, Jr., through counsel, and
unto the Honorable Court most respectfully manifest that they are serving upon
Respondents Heirs of PABLO DULALIA, SR., this Request for Admission, and
hereby ask Respondents to answer this Request for Admission within fifteen (15)
days after service hereof.

The matters which are being requested to be admitted by Respondents

Heirs of PABLO DULALIA, SR. are as follows:

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
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for Admission (a copy is herein attached as Annex “A”) submitted last

October 24, 2018, by the Respondents Jose Antonio Dulalia Justiniani,
for himself and in representation of the other heirs of Lilia Dulalia
Justiniani, which in the consequence of the express and implied
admissions of all parties was declared to be undisputed in the Decision
by this Honorable Court dated July 18, 2019 (a copy is herein attached
as Annex “B”).

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

Kindly respond promptly to the instant request for admission.

RESPECTFULLY SUBMITTED.

Iloilo City, Philippines, January 28, 2020.

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: cybilldoradodiaz@gmail.com

Copy furnished:

ATTY. GIL MARIE M. ALBA

Counsel for Respondents
Heirs of Lilia Dulilia Justiniani and
Heirs of Rafael Z. Dulalia, Sr.
Rm. 308, 3rd Floor, Golden Commercial Center
Iznart St., Iloilo City
Received by: ______________
Date: _________________
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JOSE ANTONIO DULALIA JUSTINIANI

_________________________________
_________________________________
Received by: ______________
Date: _________________

JOSE MARIA DULALIA

_________________________________
Received by: ______________
Date: _________________