Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL REGION
BRANCH 254
Las Piñas City

MOTION TO ENTER PREMISES

IN RE: Settlement of Intestate Estate of

SPOUSES VICTOR KARL GUSTAF
Special Procedure Case No.
HENNINGSSON and TERESITA
21-0071
ORCINA HENNINGSSON with
For: Special Administrator of
the aforementioned estate.
CAROLINE HENNINGSON AND
KRISTINE HENNINGSON BRADFORD,
Petitioner.
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Petitioner, CAROLINE HENNINGSON AND KRISTINE HENNINGSON

BRADFORD, through the undersigned counsel and unto this Honorable
Office most respectfully manifests that:

1. That upon the death of Sps. Henningsson, Robert Einar

Henningsson the brother of the herein petitioners, had leased and
collected the rent of the subject property located 162-A CRM Ave. BF
Homes, Almanza, Las Pinas, Metro Manila On 07 October 2022 at around
12:00 noon, in the presence of the lessee’s of the premises at 162-A CRM
Ave. BF Homes, Almanza, Las Pinas, Metro Manila.

2. On 17 August 2022, the Regional Trial Court Branch 254 of Las

Piñas City issued an Order appointing Atty. Wilson Kyle Baser as
Special Administrator of the estate of Sps. Victor Karl Gustaf
Henningsson and Teresita Orcina Henningsson (“Sps.
Henningsson”)

3. That to finally settle the estate of the deceased, petitioners, being

compulsory heirs of the deceased, seeks for the issuance of the
 court of letters of administration and to make full inventory and
accounting of their estate and settle any claims for and against such
estate prior to its distribution to the compulsory heirs in view of the
apparent neglect and continuing refusal of the other compulsory
heir (Robert) to settle such estate to the great damage and
prejudice of herein petitioners.

4. That the Notice dated 07 October 2022 together with the Abo Law
legal team led by Atty. Kyle Baser, and Order dated 17 August 2022
issued by this Honorable Court was posted at the subject property.

5. However petitioner’s brother, (Robert) called the special

administrator Atty. Kyle Baser after the said SA, together with the Taguig
City Police, Brgy. Tanod and Homeowners Association representatives of
BF Homes, Almanza Dos tried to give the notice to the lessees but
refused to receive it as they claimed at first that it is only Robert who can
receive the letter because he is the owner of the property as known to
them.

6. That herein Respondent Robert refused to confirm to Atty.

Baser that he is the one talking in the phone, but later told the Special
Administrator that he should tell to his clients “sabihin mo sa dalawang
yan, tigil tigilan na nila ang pangingialam sa property na to. By then Atty.
Baser knew that he was indeed talking to the respondent herein.

7. That, in all humility, his non-compliance with the aforesaid order

prompted our office to cite him indirect contempt for delaying the
proceedings and for disobedience of or resistance to a lawful writ,
process, order, or judgment of a court.

PRAYER

WHEREFORE, premises considered, in order to accord the Respondent

the opportunity to aptly defend himself for the charge against him before
this Honorable Office, it is most respectfully prayed that:
1. The preliminary investigation be re-opened;

2. That upon the re-opening of the preliminary investigation, the

attached subscribed and signed Counter - Affidavit of the Respondent
and Affidavit of Witnesses be admitted and to form part of the records
of the instant case; and

3. Please enter the appearance of the undersigned as counsel for the

Respondent Charlon P. Bernardo for/in the above-entitled case and
henceforth, send all pleadings, notices, orders, resolutions, and other
papers to the undersigned at the address indicated below

Respondent likewise prays for other relief, just and equitable,

under the premises.

Taguig City for Parañaque City, 6 October 2020.