Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch ____, Cebu City

FLORENCIA ABALO, for herself as CIVIL CASE NO.

representatives of ANGEL ABALO,
DOMINGO ABALO and FELICISIMA
ABALO,
Plaintiffs,

-versus-

BANCO PRIMERO DEVELOPMENT

BANK,
Defendant.
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COMPLAINT

COME now Plaintiffs, through the undersigned counsel, to this

Honorable Court, most respectfully states:

1. That plaintiffs are all of legal age, Filipinos, and with residence at
Sitio Sambag, Bulacao, Cebu City where they may be served will notices
and other processes of this Honorable Court;

2. That petitioners are one of the grand children of the late BENITA
ABASOLO ABALO, the wife of late Gregorio Abalo;

3. That the late MARIANO ABALO, father of the petitioners, is one

of the children of the late Benita Abalo;

4. That the late Benita Abasolo Abalo died sometime June 13, 1967, as
shown by the Death Certificate, machine copy of which is hereto attached
as Annex “B”, while the late Mariano Abalo sometime MARCH 22, 1998, as
shown by the Certificate of Death machine copy of which is hereto
attached as Annex “C”;

5. That the late Mariano Abalo have the following children, to wit:

a. Florencia Abalo;

b. Angel Abalo;
 c. Domingo Abalo; and

d. Felicisima Abalo;

6. That machine copies of NSO issued Certificate of Live Birth of

Florencia Abalo, Angel Abalo, and Felicisima Abalo are hereto attached as
Annexes “C” to “E”, respectively;

WHEREFORE, in view of the foregoing premises, it is most

respectfully prayed of this Honorable Court that after due notice and
hearing that petitioners Florencia Abalo, Angel Abalo, Domingo Abalo,
and together with Felicisima Abalo be declared as heirs of the late BENITA
ABASOLO-Abalo and MARIANO ABALO;

Cebu City, Philippines, April 12, 2017.

ATTY. FRANCIS GEORGE F. DINOPOL

Counsel for the Petitioners
Suite 402 G.K. Chua Bldg.
Sancianco St., Cebu City
Roll of Attorneys Number 50084
PTR No. 13263775, 1-12-2017 Cebu Capitol
IBP No. 1065126, 1-12-2017, Cebu Chapter
MCLE Compliance No. II-0014596
MCLE Compliance No. III-0021915, 06-26-2012
MCLE Compliance No. IV-0011760, 02-08-2013
MCLE Compliance No. V-0024375, 11-21-2016
Tel. No. 5151417/4141178