Republic of the Philippines
First Judicial Region
REGIONAL TRIAL COURT
Branch 26
San Fernando City, La Union
IN THE MATTER OF THE PETITION FOR THE ISSUANCE OF
ADMINISTRATION, SETTLEMENT, AND DISTRIBUTION OF ASSETS OF
THE INTESTATE ESTATE OF TEODORO N. SALANGA, JR.
EDMER T. SALANGA,
Petitioner,
SPECIAL PROCEEDING NO. 3404
-versus-
THI PHUONG LOAN SALANGA,
Oppositor.
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MANIFESTATION WITH MOTION TO ALLOW OPPOSITOR TO
CONDUCT/ENGAGE IN BUSINESS ON THE PROPERTIES INCLUDED IN
THE ESTATE OF THE LATE TEODOR0 N. SALANGA, JR.
OPPOSITOR, through the undersigned counsel unto this Honorable
Court, respectfully manifests that:
1. The petitioner and oppositor were both adjudged co-special
administrator of the estate of the late Teodoro N. Salanga, Jr.;
2. The petitioner after taking his oath has practically annexed/took-
over all the properties of the estate of the late Teodoro N. Salanga,
Jr., to the exclusion, detriment and prejudice of herein oppositor;
3. The Oppositor for the record and previous to the co-
administratorship ORDER by the Honorable Court was managing
the property at Don Joaquin St., Brgy. III, San Fernando City,
La Union under the MKS Realty of her daughter SARIFA SALANGA
and was lessor to one, Ricardo F. Simeon leasing the property for a
monthly lease of Php 10,000.00 for a guaranteed period of two (2)
years;
4. The petitioner through intimidation and false assertion that he is
the sole Administrator of the property demanded from the lessee,
Ricardo F. Semion to vacate the property he is leasing from the
oppositor through the MKS Realty and out of fear of not being able
1|Page Manifestation with Motion to Allow Oppositor to Conduct/
Engage in Business on the Properties Included in the Estate
of the Late Teodoro N.Salangg,Jr.
to get his merchandise if and when the petitioner makes good of
his threat that he will be physically moved-out of the leased
property, hurriedly left the premises taking with him his
merchandise, thus cutting short his intended lease agreement with
the oppositor;
5. The petitioner had consequently annexed/took-over totally in his
favor the said property at Don Joaquin St., Brgy. III, SFLU by
constructing a concrete wall to block ingress and egress on the
property of any one including herein oppositor;
6. Similarly, petitioner to date has totally took over the management
of the Salanga Building located in Brgy. Catbangen, San Fernando
City, La Union and even demands that oppositor also vacate her
unit in the building because according to the petitioner, she has
no right over the property;
7. The Salanga Building is declared in the names of the petitioner
and her husband, the late Teodoro N. Salanga, Jr.; thus, she has
all the rights to stay there and manage the property considering
that the same is a conjugal property built from the money of both
oppositor and her husband;
8. The Oppositor used to occupy one (1) unit of the ground floor for
her PHO SAIGON Restaurant business, which was
unceremoniously closed because the petitioner caused the
destruction of the restaurant kitchen; thus, business could no
longer operate;
9. The oppositor also before the co-administratorship order was also
renting out the rooms/units at the Salanga Building which has
been the case even during the time her husband was still alive; but
to date, all the units are now under the control and management
of the petitioner and solely renting the units to his own set of
tenants after he was able to forced-out the tenants of the oppositor
to her prejudice and detriment;
10. The petitioner has controlled and managed one hundred percent
(100%) the lot property where the gasoline refilling business of
the Chan Family is situated; the Chan Family originally leased
the property from the late Teodoro N. Salanga, Jr., which the
petitioner took over since 2013 even before Teodoro N. Salanga,
Jr., died in 2014; in fact, he re-negotiated the original lease
contract with the Chan family which he now controls wholly, to the
exclusion, detriment, and prejudice of herein petitioner;
11. To date, the oppositor as with the other children, especially
Sarifa Salanga, who is doing business under MKS Realty, where
she appointed herein oppositor as her Attorney-In-Fact to manage
the affairs of her MKS Realty especially the Don Joaquin property
are now left with NO PROPERTY TO CO-MANAGE, since all the
properties in the estate of the late Teodoro N. Salanga, Jr., is now
2|Page Manifestation with Motion to Allow Oppositor to Conduct/
Engage in Business on the Properties Included in the Estate
of the Late Teodoro N.Salangg,Jr.
under the control and sole management of the petitioner, Edmer
Salanga, despite opposition from the oppositor; and
12. The Oppositor has no source of income to date and will
continue to be so if continuously deprived by the petitioner of her
co-administratorship of the properties subject in this intant case.
PRAYER
WHEREFORE, premises considered, herein Oppositor most humbly
and respectfully prays unto this Honorable Court that this
MANIFESTATION be noted and her MOTION TO BE ALLOWED TO
CONDUCT/ENGAGE IN BUSINESS BE GRANTED in the interim period
while the proceedings on the allowance/probate of the alleged Last Will,
Testament and Codicil of the late Teodoro N. Salanga, Jr., filed by the
petitioner is being heard by the Honorable Court in the following subject
properties included in his estate, namely;
1. Don Joaquin lot properties – (i). a parcel of land covered by TD
No. 93-003-771-R under TCT No. T-O-253 consisting of ONE
HUNDRED NINETY-THREE (193) square meters; (ii). a parcel of
land covered by TD NO. 00-003-57381 under TCT No. T-52788
consisting of TWO HUNDRED FORTY-SIX (246) square meters;
and (iii). a parcel of land covered by TD NO. 93-003-773 under TCT
No. T-0-80 consisting of FIFTY THREE (53) square meters, all of
which are located at Brgy III, San Fernando City, La Union in the
name of oppositor’s late husband, Teodoro N. Salanga, Jr., and
used to be rented/leased out by the oppositor for commercial
purposes at Php10,000.00 to Php 15,000.00 per month, per
property; and for this motion, is intended to be leased out to
prospective lessee for at least the same price as the previous lease
agreement between Php 10,000.00 to Php 15,000.00 per month, per
property;
2. Catbangen lot property – covered by TD NO. 93-022-9254 under
TCT No.20162 consisting of ONE THOUSAND TWO HUNDRED
EIGHTY-SIX (1,286) square meters located at Brgy. Catbangen,
SFLU, of which a small portion was previously rented out to one,
Thelma Marquez for Php 5,000.00 monthly rental, but agreement
was rescinded on the ground that the lessee did not comply with
the contract agreement with the oppositor; and for this motion, is
intended to be leased out to prospective lessee at a price depending
on the portion to be leased;
3. One (1) unit of the ground floor of the Salanga Building in
Catbangen, San Fernando City, La Union – and for this motion, is
intended for the re-opening of oppositor’s PHO SAIGON Restaurant
business, which business had a monthly gross sales of Php
17,500.00 (average), and/or for such other business as may be
deemed more feasible by the oppositor to pursue, including lease of
the same; the whole of Salanga Building property is covered by TD
3|Page Manifestation with Motion to Allow Oppositor to Conduct/
Engage in Business on the Properties Included in the Estate
of the Late Teodoro N.Salangg,Jr.
NO. 12-022-89761 in the name of the oppositor and the late
Teodoro N. Salanga, Jr., and
4. All of the four (4) units/rooms (including oppositor’s
unit/room) at the 2nd floor and the two (2) units/rooms at the
3rd floor of the Salanga Building in Catbangen, San Fernando
City, La Union; and for this motion, is intended for oppositor’s rental
business which used to gross at least Php 17,000.00 per month
before, when she had control and management of the building and
the units/rooms.
It is further prayed from the Honorable Court to order petitioner
(1). to refrain from further committing acts of harassment against
the oppositor, which to include petitioner’s workers and security
guards he hired and posted in the Salanga Building; (ii). to allow
oppositor free access and movement without restrictions within the
Salanga Building premises and in all the properties being asked by
the oppositor relative to this Motion; (iii). and to stop the ban
imposed by him against all persons (e.g. friends, clients, counsel,
and the likes) visiting the oppositor, including workers/helpers
contracted by the oppositor to help her in the management of her
affairs in the building, including what is being prayed for in this
MOTION; and
Other relief and remedies as may be deemed just and equitable under
the premises are likewise prayed for.
RESPECTFULLY SUBMITTED.
San Juan, La Union for San Fernando City, La Union, Philippines,
this 15th day of September, 2021.
MOSUELA - GONZALES & ASSOCIATES LAW OFFICES
Counsel for the Oppositor
Unit 1 San Juan LGU Multi-Purpose Center
Santa Rosa de Lima Street, Ili Sur, San Juan, 2514 La Union
By:
JAIME C. GONZALES, JR.
IBP Roll No. 68552, May 29, 2017
IBP O.R. No. 122362, January 05, 2021 (LU CHAPTER)
PTR No. LU 5453746, January 04, 2021
MCLE Comp. No. VI-0007263, valid until April 14, 2022
CP No. 0917 518 2410 / E-mail Address:
[email protected]4|Page Manifestation with Motion to Allow Oppositor to Conduct/
Engage in Business on the Properties Included in the Estate
of the Late Teodoro N.Salangg,Jr.
NOTICE OF HEARING
THE CLERK OF COURT
REGIONAL TRIAL COURT
BRANCH – 26, SAN FERNANDO CITY,
2500 LA UNION
G R E E T I N G S!
Please take notice that the undersigned will be submitting this
MANIFESTATION WITH MOTION TO ALLOW OPPPOSITOR TO
CONDUCT/ENGAGE IN BUSINESS for the consideration and approval of
the Honorable Court on November 25, 2021 at 8:30 o’clock in the morning.
JAIME C. GONZALES, JR.
COPY FURNISHED:
ATTY. GAMALIEL TAQUED
#1 Rizal Ave., Brgy. Ilocanos Sur
San Fernando City, 2500 La Union
ACP ROBERT FANGAYEN, JR.
City Prosecutor’s Office
RTC Compound, Sevilla
San Fernando City, 2500 La Union
EXPLANATION
Copy of this MANIFESTATION WITH MOTION TO ALLOW
OPPPOSITOR TO CONDUCT/ENGAGE IN BUSINESS were served to the
parties enumerated above, both by electronic mail and registered mail with
return card due to time and distance constraints, and for lack of personnel
to effect personal delivery of same.
JAIME C. GONZALES, JR.
5|Page Manifestation with Motion to Allow Oppositor to Conduct/
Engage in Business on the Properties Included in the Estate
of the Late Teodoro N.Salangg,Jr.
