FORM_33

Republic of the Philippines

REGIONAL TRIAL COURT
Third Judicial Region
Branch IV
Angeles City

RE: IN THE MATTER OF THE

ISSUANCE OF THE SECOND
OWNER’S DUPLICATE COPY
OF TRANSFER CERTIFICATE
OF TITLE NO. RGR4444 OF THE
REGISTRY OF DEEDS FOR
MUNICIPALITY OF PORAC

LRC Case No. RR-4444

BARTHOLOMEW H. ALLEN,
Petitioner.
x----------------------x

PETITION

COMES NOW, the Petitioner, Bartholomew H. Allen, by and

through the undersigned counsel and unto this Honorable Court,
respectfully alleges that:

1. The petitioner is of legal age, Filpino, single, and a

resident of #111 St., Jude, Brgy. Alfonso, Angeles City,
Pampanga, Philippines,  where he may be served with
court processes;

2. The petitioner is a lawful and registered owner of a parcel

of land together with the improvements therein, identified
as Lot 20 Blk 54 of consolidation subdivision plan (LRC)
Pcs-13265 located in the Municipality of Porac, Province
of Pampanga, with an area of TWO HUNDRED EIGHTY
(280) SQ. METERS, more or less, embraced by Transfer
Certificate of Title No. 0000000 duly issued by the
Registry of Deeds for Municipality of Porac which parcel
of land is particularly described as follows:

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FORM_33

(Transfer Certificate of Title No. 0000000)

Registry of Deeds for Municipality of Porac

“A PARCEL OF LAND (Lot 20 Blk 54 of consolidation

subdivision plan (LRC) Pcs-13265, being a portion of the
consolidation of Lots 4751-A and 4751-B (LRC) Psd-
50533, Lot 3, Psd-100703, Lot 1, Psd150980, LRC Rec.
Nos. Nos. N-27024, 51768, 89632, N-11782, N-13466,
and 21071 situated in the Bo. of San Donisio, Mun of
Porac, Prov of Pampanga, Is. of Luzon. Bounded on NE.,
point 4 to 1 by Road Lot 22, on...to the point of beginning;
containing an area of (280) square meters more or less..."

A copy of Transfer Certificate of Title No. 0000000 is

hereto attached as Annex “A”;

3. The petitioner usually kept the owner’s duplicate copies of

all the certificate of titles for its real estate properties in
the vault together with all the other important documents
of the petitioner. The said vault is under the control and
supervision of the petitioner;

4. After diligent search to the vault of Transfer Certificate of

Title No. 0000000, the same could not be found;

5. The petitioner exerted all efforts to look and determine the

whereabouts of the said certificate of title but despite
these efforts, the petitioner still failed to locate the said
certificate and apparently they were misplaced and
deemed lost;

6. Consequently, the petitioner executed an Affidavit of

Loss, which was registered with the Register of Deeds for
Municipality of Porac and annotated at the back of the
original Transfer Certificate of Title No. 1111111 in the
possession of said Office under Entry No. RGR1994.

A copy of the Affidavit of Loss is hereto attached

as Annex “B” and made as an integral part hereof;

7. The issuance of the Second Owner’s Duplicate Copy of

TCT No. 0000000 can be based and drawn from a
certified true copy of the original copy thereof secured by
petitioner from Registry of Deeds for Municipality of
Porac.

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FORM_33

A copy of the certified true copy of the original copy is

hereto attached as Annex “C”;

8. Subject property covered by TCT No. 0000000 is also

covered by Tax Declaration No. 19941004 issued by the
Office of the City Assessor.

A copy of Tax Declaration is hereto attached as Annex

“D”;

9. The petitioner is up to date in the payment of the real

estate taxes for the subject property as evidenced by a
Certification issued by the Office of the City Assesso.

A copy of Certification of Payment is attached as Annex

“E”.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of

the Honorable Court that after due notice and hearing, a decision be
rendered by this Honorable Court directing the Registry of Deeds of
Municipality of Porac to cause the issuance of a new Owner’s
Duplicate Copy of TCT No. 0000000 with like faith and integrity as the
lost certificate of title for all legal intents and purposes.

          Other reliefs and remedies as may be deemed just and

equitable under the premises are likewise prayed for.

Respectfully submitted.

Angeles City, Philippines, 12 June 2020.

(Sgd.) ATTY. RAYMOND G. RONQUILLO

Counsel for Petitioner
RONQUILLO & ASSOCIATES LAW OFFICE
Rm. 404 RGR Bldg., McArthur Hi-way, Salapungan, Angeles City
IBP Lifetime No. 000000/Pampanga
PTR No. 0000000/January 02, 2020/Angeles City
Supreme Court Roll of Attorney’s No. 00000
MCLE Compliance No. V–0000000/October 01, 2019
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FORM_33

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, Bartholomew H. Allen, Filipino, of legal age, after been duly

sworn, depose and state that:

1. I am the Petitioner in the foregoing Petition.

2. I caused the preparation of the foregoing Petition which I
have read and understood.
3. I hereby affirm that all factual allegations contained in the
said Petition are true and correct of my own personal
knowledge and belief, as well as true and correct basis of
authentic documents and records in my possession.
4. I further certify that I have not commenced any other
action involving the same issues before the Supreme
Court, Court of Appeals or any division thereof or any
tribunal or agency; and to the best of my knowledge no
such action is pending before the Supreme Court, Court,
Court of Appeals or any division thereof or any tribunal or
agency.

In the event that any action involving the same should be made
known, I hereby bind myself to report the same within five (5) days
from knowledge thereof to this Honorable Court.

IN WITNESS WHEREOF, I hereunto set my hand this 12 th day

of June 2020 at Angeles City, Philippines.

(Sgd.) BARTHOLOMEW H. ALLEN

Petitioner

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FORM_33

SUBSCRIBED AND SWORN to before me, this 12th day of June

2020, in Angeles City, Philippines, by the following whom I have
identified through competent evidence of identity and who exhibited to
me the same as follows:

PERSONS COMPETENT EVIDENCE OF

IDENTITY

BARTHOLOMEW H. ALLEN UMID No. CRN-0062-1245678-9

Date of Issue: N/A

Doc. No. 33; ATTY. RENEE MIRIELLE G. DELA CRUZ

Notary Public for Angeles City
Page No. 07; DELA CRUZ & ASSOCIATES LAW OFFICE
Book No. I; Rm. 209 PS Bldg., McArthur Hi-way, Salapungan,
Angeles City, Philippines
Series of 2020. Roll No. 00000, June 4, 2017
Commission Serial No. 0000-000
Valid until December 31, 2021
IBP Lifetime No. 000000/Pampanga
PTR No. 0000000/January 04, 2020/Angeles City

EXPLANATION

This certifies that personal service was not resorted to for the
reason that due to time, distance and manpower constraints, the
same is not practicable.

(Sgd.) ATTY. RAYMOND G. RONQUILLO

Copy Furnished:

CLERK OF COURT
Regional Trial Court
Branch IV, Angeles City

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