REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

7TH Judicial Region
Branch 12
Cebu City

Guardian’s Bond for the

Property of the Minors
Stephanie and Stephan, both Surnamed Graph

Sp. Proc. No. M-3629

Andrei A. Graph
Petitioner,

x----------------------------------------------------------------------x

PETITION

COMES NOW, Petitioner Andrei A. Graph, by the undersigned counsel,

and unto this Honorable Court, respectfully avers that:

1. Petitioner, Andrei A. Graph is of legal age, widower, and with

residence at Unit 65 One Oasis, Mabolo, Cebu City where he may
be served with notices and other court processes of this Honorable
Court.

2. Petitioner is the father of both minors Stephanie (13 years old) and
Stephan (12 years old) both surnamed Graph. The said minors are
all living with the Petitioner at the same address. Attached
herewith and marked as Annexes “A” and “B” are photocopies of
the respective Certificates of Live Birth of the above-mentioned
minors.

3. Petitioner and the minor’s mother Steffi Graph are spouses, they
having been married on May 9, 2001. Attached herewith and
marked as Annex “C” is a photocopy of their Marriage Contract.

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 4. Steffi Graph met her untimely demise on January 30, 2017.
Attached herewith and marked as Annex “D” is a photocopy of her
Certificate of Death.

5. During her lifetime, Steffi Graph was insured under Life Insurance
Policy No. 924924 with insurance coverage of ONE MILLION PESOS
(P 1,000,000.00) from the Pru Life UK Insurance Corp.

6. The insured, Steffi Graph designated her two children, Stephanie

and Stephan, as his beneficiaries, Stephanie being entitled to FIVE
HUNDRED THOUSAND PESOS (P 500,000.00) and Stephan to
another FIVE HUNDRED THOUSAND PESOS (P 500,000.00).
Attached herewith and marked as Annex “E” is a Certification from
Pru Life UK Insurance Corp.

7. The insurance proceeds, however though already payable to the

said minors, cannot be released except through their guardian and
upon posting of a guardianship bond.

8. Though Petitioner is already considered as the legal guardian of

minors Stephanie and Stephan, the former being the father of said
minors, there is still a necessity of posting guardianship bond
considering that the property of the said minors exceeds FIFTY
THOUSAND PESOS (P 50,000.00). Hence, this petition.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that

this Honorable Court fix and approve a bond over the said insurance
proceeds in favour of minors Stephanie and Stephan, both surnamed Graph,
amounting to ONE MILLION PESOS (P 1,000,000.00) and to allow petitioner,
Andrei A. Graph to file a bond pursuant thereto.

Other reliefs and remedies just and equitable under the premises, are
likewise prayed for.

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Cebu City, Philippines, 15 February 2017.

ATTY. KVYN R. HONORIDEZ

Counsel for Petitioner
Roll of Attorneys No. 2222
MCLE Compliance Certificate V No. 1112, 1/3/2017
PTR No. 2222, 1/5/2017, Cebu City
IBP No. 2222, Lifetime, Cebu City
Room 3, The Walk, Asiatown, IT Park
Lahug, Cebu City, 6000

REPUBLIC OF THE PHILIPPINES)

CITY OF CEBU )S.S.
X- - - - - - - - - - - - - - - - - - - - - - - - - - - - -/

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, ANDREI A. GRAPH, of legal age, after having been duly sworn in accordance
with law, depose and state that:

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the same
issues in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;

5. To the best of my knowledge and belief, no such action or proceeding is

pending in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;

6. If I should thereafter learn that a similar action or proceeding has been

filed or is pending before the Supreme Court, the Court of Appeals, or any

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other tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this Honorable Court.

___________________________
Andrei A. Graph
Affiant

SUBSCRIBED AND SWORN to before me this 16th day of February 2017

at Cebu City affiant exhibiting to me his Driver’s License with No. GO6-83359
issued on May 9, 2016 at Cebu City.

ATTY. KATRINA M. REGALADO

Notary Public within and for the territorial jurisdiction of
The RTC of Cebu City, San Fernando, and Carcar City
Notarial Commission No. 144
Until December 31, 2018
Roll of Attorneys No. 2223
MCLE Compliance Certificate V No. 1113, 1/3/2017
PTR No. 2223, 1/5/2017, Cebu City
IBP No. 2223, Lifetime, Cebu City
Suite 04, RC Towers
Talamban, Cebu City, 6000