Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Davao City
Branch 6

ANTHONY A. MERCADO
Petitioner,
- versus - Spec. Pro. No.: __________
For: Consolidation of Ownership
in Pacto De Retro Sale

MARTHA KAYE C. AGONCILLO

Respondent,
X--------------------X

PETITION
PETITIONER, in his own behalf and unto this Honorable
Court, respectfully states:

STATEMENT OF FACTS

1. That the petitioner bought under pacto de retro

from the vendor, MARTHA KAYE C. AGONCILLO a certain piece of
real property, as evidenced by a Deed of Sale dated December 06,
2017, Attached as Annex “A”;

2. That the date for repurchase on May 02, 2019,

having expired and the vendor not being able to repurchase the
same under the terms and conditions therein stated, the ownership
over the said real property has now become consolidated in the
vendee-petitioner;

3. That for purposes of recording in the Registry of

Property the said consolidation or ownership in the vendee-petitioner,
it is necessary that a judicial order be issued to this effect, pursuant
to the provisions of Art. 1607 of the New Civil Code.

PRAYER
WHEREFORE, after due notice to the vendor, it is respectfully
prayed that an order be issued by this Honorable Court, ordering the
consolidation of ownership on the real property herein mentioned in
the vendee-petitioner for all legal purposes.

PESPECTFULLY SUBMITTED.

Davao City, Philippines, 06 March 2020.

SANTOALLA and Associates Law Offices

Counsel for the Petitioner
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City
Tel. Nos.: (082) 282-3662
ssantoalla@yahoo.com

By:
Sgd.
ATTY. STEPHANIE M. SANTOALLA
IBP NO. 071717, 12/12/19, Davao City
PTR NO. 071717, 12/12/19, Davao City
ROLL ATTORNEY NO. 11077
MCLE Comp. No. IV-0004785, 3/2/19
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City