Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch 14
Manila

In the matter of the PETITION FOR

SETTLEMENT OF THE INTESTATE
ESTATE OF THE LATE ARMANDO
TUDLA

SPECIAL PROCEEDINGS
No.: 13130989

ESTRELLITA URRUTIA TUDLA

a.k.a. ESTRELLA URRUTIA TUDLA
or ESTRELLA TUDLA

MOTION TO INTERVENE

COMES NOW, Mrs. Hou Kou, by his under counsel, to this

Honorable Court respectfully prays that she be permitted to intervene in
this case as a party plaintiff on the ground that she has legal interest in
the matter under litigation, and that she may be adversely affected in
these proceedings as shown in the attached Complaint In Intervention.
WHEREFORE, It is respectfully prayed that Mrs. Hou Kou be
allowed to intervene as a party plaintiff and the attached complaint be
admitted and served on the defendant.
Manila Philippines, April 17, 2015

ATTY. OSCAR RYAN SANTILLAN

Counsel for Plaintiff

Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch 14
Manila

In the matter of the PETITION FOR

SETTLEMENT OF THE INTESTATE
ESTATE OF THE LATE ARMANDO
TUDLA

SPECIAL PROCEEDINGS
No.: 13130989

ESTRELLITA URRUTIA TUDLA

a.k.a. ESTRELLA URRUTIA TUDLA
or ESTRELLA TUDLA

COMPLAINT IN INTERVENTION
COMES NOW the plaintiff by the undersigned attorney, and unto
this Honorable Court, respectfully alleges
1. That plaintiff is of legal age and a resident of Manila City
and defendant is likewise of legal age and resident of Manila City.
2.That, on March 25, 2014 defendant borrowed from plaintiff
the sum of TEN MILLION PESOS (Php 10,000,000.00), which
indebtedness was to be paid and earn interest in accordance with
the terms of a promissory note which was executed by defendant on
that same date which instrument is copied verbatim, hereunder:
For value received, I promise to pay to Mrs. HOU KOU
the sum of TEN MILLION PESOS (Php 10,000,000.00, within
one (1) year from the date of this promissory note, plus
interest at the rate of 12% per annum.
Manila, Philippines
March 25, 2014

(Sgd,) Armando Tudla

3. That the payment of said indebtedness is now overdue, and

defendant has failed and refused and still fails and refuses, to pay
the same, notwithstanding repeated demands from plaintiff.
4. That defendant likewise failed to any interest due on the
aforementioned obligation.
WHEREFORE, It is respectfully prayed that judgment issued in favor of
plaintiff and against defendant, ordering the latter:
1. To pay to plaintiff the sum of Php 10,000,000.00, plus
interest thereon at the rate of 12% per annum from March 25, 2014
until complete payment is made.
Manila Philippines, April 17, 2015

ATTY. OSCAR RYAN SANTILLAN

Counsel for Plaintiff