REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH ______
__________ CITY

IN THE MATTER OF THE INTESTATE

ESTATE OF JOSE C. SERMONIA,

SP. PROC. NO._________

Petition for Letters of
Administration

ZENAIDA T. SERAFICA,
Petitioner.
x ------------------------------------------------- x

PETITION

PETITIONER ZENAIDA T. SERAFICA, by counsel, unto this Honorable Court

respectfully states:

1. Petitioner is of legal age, single, and a resident of Unit 173, Brentwood

Heights Townhouse, Jerusalem Street, Multinational Village, Parañaque, Metro Manila.

2. On 4 October 1995, petitioner was employed by Mr. Jose C. Sermonia as

a Project Manager for his various development projects. A copy of the employment

contract duly signed by Mr. Sermonia is attached hereto and made an integral part hereof

as Annex "__".

3. As part of petitioner's employment package, she was entitled to a sign-in

fee of P25,000.00, 13th and 14th month pays and a total of 30 days vacation and sick

leave per year.

 4. In the course of petitioner's employment, she advanced with the full

knowledge and consent of Mr. Sermonia, various sums totalling Two Hundred Thirty

Seven Thousand One Hundred Ten Pesos and Five Centavos (P237,110.05) in payment

of contractors and suppliers to expedite the development of his various projects,

including Vacations Grande and Ina Mansions in Baguio City.

5. On 15 January 1996, Mr. Sermonia unceremoniously terminated the

petitioner's services without reimbursing her for the advances she made in the amount of

P237,110.05. Neither was she paid the agreed sign-in fee of P25,000.00 and her salary

for the period 1-15 January 1996 in the total amount of Fifty Thousand Pesos

(P50,000.00). Copies of the Register Listing prepared by petitioner showing the amounts

advanced by and due her together with the supporting receipts for the period from 1

October 1995 to 6 February 1996 are attached hereto and made integral parts hereof as

Annexes "__" to and "__".

6. Petitioner's counsel sent several demand letters to Mr. Sermonia to pay

and settle the aforesaid amounts representing the advances and unpaid salaries due her.

However, despite receipt of said letters, Mr. Sermonia refused to settle his obligation.

Copies of the demand letters dated 11 March and 22 April 1996 are attached hereto and

made integral parts hereof as Annexes "__" to "__".

7. While petitioner was claiming reimbursement of her advances, unpaid

salary and employment benefits from Mr. Sermonia, the latter suffered a heart attack and

died on 11 August 1997 without leaving a will. A copy of Mr. Sermonia's certificate of

death is attached hereto and made an integral part hereof as Annex "__".

8. At the time of his death, Mr. Sermonia (the "decedent") was a resident of
No. 722 Calicante St. corner North Batangas St., Ayala Alabang Village, Muntinlupa,

which is within the jurisdiction of this Honorable Court.

9. The names and residence of the decedent's surviving heirs are as follows:

Name Age Relation Residence

Agnes Prieto Sermonia ___ spouse No. 722 Calicante St. corner
North Batangas St., Ayala Alabang
Village, Muntinlupa
_________________ ___ _______ _____________________
_________________ ___ _______ ______________________
_________________ ___ _______ ______________________

10. The decedent left the following real and personal properties:

Character Location/Source Probable

Value

Parcel of land Shangrila Vill., Pansol, Laguna P2,300,000.00

Parcel of land Valle Verde, Pasig, M.M. 12,000,000.00
Condominium unit Eurovilla Penthouse, Alfaro St., M.C. 4,083,450.00
Condominium units (26) Ina Mansion Condo., Baguio City 15,000,000.00
Parcel of land Alfonso, Cavite 2,502,500.00
Parcels of land (9 lots) San Pascual, Batangas 2,550,000.00
Parcel of land Puerto Galera, Oriental Mindoro 3,850,000.00
Parcels of land (17 lots) Mataas na Kahoy, Batangas 1,872,500.00
Cash --------- 750,000.00
Shares of stocks Evercrest Golf Club & Resort Inc. 2,250,000.00
Shares of stocks Calatagan Golf & Country Club 250,000.00
Shares of stocks Rural Bank of San Teodoro 25,000,000.00
Jewelries --------- 300,000.00

11. As far as petitioner knows, the following are the names and respective

residences of the decedent's other creditors:

Names Addresses

_______ _____________
 _______ _____________
_______ _____________

12. Since the time of Mr. Sermonia's death on 11 August 1997, neither his or

next of kin has applied for administration of his estate.

13. Being a creditor of the decedent, petitioner is among those allowed to act

as administrator of the estate and possesses all the qualifications and none of the

disqualifications to be appointed as such.

PRAYER

WHEREFORE, it is respectfully prayed that after due notice and hearing, letters

of administration of the estate of JOSE C. SERMONIA be issued in favor of petitioner.

Other reliefs just and equitable under the premises are likewise respectfully

prayed for.

_______________, ________ 1999.

TAN & VENTURANZA LAW OFFICES

Counsel for the Petitioner
2704 East Tower, PSE Centre
Exchange Road, Ortigas Center
1605 Pasig City

By:

MARTIN L. BUENAVENTURA
PTR No. 298269/01.21.99/Quezon City
IBP No. 466829/01.21.99/Quezon City
 VERIFICATION/CERTIFICATION

I, ZENAIDA T. SERAFICA, of legal age, single, Filipino citizen after having

been duly sworn to in accordance with law hereby depose and state that:

1. I am the petitioner in the above-entitled case;

2. I have read the allegations contained in said petition which are true and
correct of my own knowledge;

3. I have not commenced any other action, proceeding involving the same
issues before the Supreme Court, the Court of Appeals, or to any other court, tribunal or
agency;

4. To the best of my knowledge, no such action or proceeding is pending

before the Supreme Court, the Court of Appeals, or any other court, tribunal or agency;

5. If I should learn that a similar action or proceeding has been filed or is

pending before the Supreme Court, the Court of Appeals, or any other court, tribunal or
agency, I hereby undertake to report said fact within five (5) days therefrom to this
Honorable Court.

______________________
ZENAIDA T. SERAFICA

SUBSCRIBED AND SWORN to before me this day of _______1999,

affiant exhibiting to me her Community Tax Certificate No. 00003324 issued at Quezon
City on July 1, 1998.

Doc. No. ;
Page No. ;
Book No. ;
Series of 1999.
/conversion/tmp/activity_task_scratch/632651933.doc