AFFIDAVIT OF HEIRSHIP

I, SANTIAGO JR. ROBERTO DELA CRUZ, of legal age, married, a Filipino citizen, and
a resident of Brgy. Linmansangan, Mangatarem, Pangasinan, after having been duly
sworn to in accordance with the law, hereby depose and state as follows:
1. That I am one of the surviving legal heirs of our deceased mother, Natividad
Arellano Roberto Dela Cruz, who passed away on September 18, 1949, at the
age of 25.
2. That Natividad Arellano Roberto Dela Cruz was the daughter of our grandmother,
Regina Arellano Roberto.
3. That Regina Arellano Roberto passed away intestate on April 16, 1989, at the
age of 94, leaving behind a parcel of land registered in her name under "REGINA
ARELLANO," and without a will. The following are the relevant Tax Declarations
concerning the property before her death:
a. Tax Dec. No. 8 (Year 1985): Residential and Agricultural Land with an area
of 3,531 sqm., located at Brgy. Linmansangan, Mangatarem, Pangasinan.
b. Tax Dec. No. 24 (Year 1985): Agricultural Land with an area of 4,765 sqm.,
located at Brgy. Linmansangan, Mangatarem, Pangasinan
c. Tax Dec. No. 34 (Year 1985): Irrigated Rice Land with an area of 8,124
sqm., located at Brgy. Bunlalacao, Mangatarem, Pangasinan.
4. That all pertinent documents related to the aforementioned Tax Declarations, as
well as other subsequent Tax Declarations, are currently in the custody of Pacita
Roberto Cortes, one of the children of the deceased Agapito Arellano Roberto.
5. That Agapito Arellano Roberto, who passed away on June 19, 2015, was one of
the children of Regina Arellano Roberto and the brother of our deceased mother,
Natividad Arellano Roberto Dela Cruz.
6. That upon review of the official records, it was discovered that the above-
referenced properties have been transferred to the children of Agapito Arellano
Roberto, without the knowledge or consent of other legal heirs, including myself
and my late sister, Erlinda Roberto Dela Cruz Bergonia, who passed away on
March 17, 2024.
7. That in support of my legal relationship to our deceased mother and
grandmother, I have attached photocopies of my Certificate of Live Birth,
Barangay Certification, and Pedigree Chart/Family Tree.
8. That pursuant to the provisions of Article 924 of the Civil Code of the Philippines,
we, the legal heirs, are entitled to inherit the property that our mother was
supposed to inherit from our grandmother by the right of representation, as well
as all other rights appurtenant thereto.
9. That I am executing this Affidavit to attest to the truthfulness and veracity of the
foregoing facts.
IN WITNESS WHEREOF, I have hereunto set my hand this 20th day of November, 2024,
at Lingayen, Pangasinan.

SANTIAGO JR. ROBERTO DELA CRUZ

Affiant
SUBSCRIBED AND SWORN to before me this ____ day of ___________, 2024 at
___________________________. Further, I certify that I personally examined the
herein affiant that he voluntarily executed and fully understood his statements.

________________________
Administering Officer
 REPUBLIC OF THE PHILIPPINES
MUNICIPAL TRIAL COURT
Branch xxx
Province of Lingayen, Pangasinan

SANTIAGO JR. ROBERTO DELA CRUZ,

Petitioner, GR No. _______________
- versus -
PACITA ROBERTO CORTES FOR: JUDICIAL PARTITION
LOLITA ROBERTO BUENO,
Respondents.
x----------------------------------------------------x

COMPLAINT

COMES NOW the petitioner, through the undersigned counsel, and unto this Honorable
Court, most respectfully avers as follows:
1. The petitioner, SANTIAGO JR. ROBERTO DELA CRUZ, is of legal age, married,
a Filipino citizen, and a resident of Brgy. Linmansangan, Mangatarem,
Pangasinan.
2. The respondents are:
o A) PACITA ROBERTO CORTES, of legal age, widowed, a Filipino citizen,
and a resident of Brgy. Linmansangan, Mangatarem, Pangasinan; and
o B) LOLITA ROBERTO BUENO, of legal age, married, a Filipino citizen,
and a resident of Brgy. Quetegan, Mangatarem, Pangasinan.
3. The petitioner is one of the surviving grandchildren and legal heirs of REGINA
ARELLANO ROBERTO, who died intestate on April 16, 1989, at the age of 94.
4. The deceased REGINA ARELLANO ROBERTO left a certain parcel of land
registered under her name "REGINA ARELLANO" without a will, with the
following latest Tax Declarations prior to her death:
o Tax Dec. No. 8 (Year 1985): Residential and Agricultural Land, 3,531
sqm., located at Brgy. Linmansangan, Mangatarem, Pangasinan.
o Tax Dec. No. 24 (Year 1985): Agricultural Land, 4,765 sqm., located at
Brgy. Linmansangan, Mangatarem, Pangasinan.
o Tax Dec. No. 34 (Year 1985): Irrigated Rice Land, 8,124 sqm., located at
Brgy. Bunlalacao, Mangatarem, Pangasinan.
5. Upon verification from the official records, the petitioner has confirmed that the
properties of the deceased grandmother have been transferred to the children of
Agapito Arellano Roberto—namely, Pacita Roberto Cortes, Lolita Roberto Bueno,
Conrado Roberto, and Emerito Roberto.
6. The properties of REGINA ARELLANO were transferred to the aforementioned
four siblings without the knowledge or consent of the other legal heirs, including
the petitioner.
7. As one of the legal heirs, the petitioner sought to resolve the issue through
mediation before the Punong Barangay of Brgy. Linmansangan, Mangatarem,
Pangasinan, on September 28, 2024.
8. Despite three consecutive mediation sessions, which ended on October 26,
2024, the respondents refused to engage or reach a settlement, demonstrating
an unwillingness to resolve the matter.
9. Due to the respondents' persistent unwillingness to settle, the petitioner was
compelled to file this petition to seek legal redress.
10. To support this petition, the petitioner has executed the attached Affidavit.

Respectfully submitted,
Atty. Florentino Pena
Legal Counsel