REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
Branch _____
Taguig City

IN RE: PETITION FOR THE REISSUANCE OF

NEW OWNER’S DUPLICATE OF THE
TRANSFER CERTIFICATE OF TITLE Petition No. ________
NO. 12345 FOR THE REGISTRY OF
DEEDS OF TAGUIG CITY

JUAN DE LA CRUZ,
Petitioner.
x---------------------------------------------------------------x

PETITION

Petitioner, through the undersigned counsel, to the Honorable Court most respectfully
states:

1.That petitioner is Filipino, of legal age, married to Maria S. De La Cruz, and presently
residing at Sabang, Lipa City, Batangas, where notices, orders and other legal processes may be
served;

2. That petitioner is the registered owner of a parcel of land, the technical description and
petitioner’s certificate of title thereto being found in evidence by:

TRANSFER CERTIFICATE OF TITLE

No. 12345

A parcel of land (Lot 13, Blk. 23 of the subd. Plan Psd-13-001602, being a portion of Lot
10117, MCadm 590-D,-Taguig Cad. Mapping, (Pres. Proc. No. 461, Portion) , L.R.C. Rec. No.),
situated in Ft. Bonifacio, Taguig, M.M., Island of Luzon. Bounded on the SE., along line 1-2 by
lot 14; on the SW., along line 2-3 by Lot 12; on the NW., along lines 3-4-5 by Road Lot 22; and
on the NE., along line 5-1 by Road Lot 24, all of Blk. 23 of the subd. Plan. Beginning at a point
marked “1” on the plan, being S. 82 deg. 41’W., 3,828.26 m. from BLLM No. 1, MCadm 590-D,
Taguig: thence S. 62 deg. 39’W., 17.00 m. to 2: N. 27 deg. 21’W., 25.00 m. to point 3: N. 62 deg.
39’E., 14.17 m. to point 4: S. 72 deg. 23’E., 4.00 m. to point 5: S. 27 deg. 21’E., 22.17 m. to the
point of beginning, containing an area of FOUR HUNDRED TWENTY ONE (421) SQUARE
METERS. All points referred to are indicated on the plan and are marked on the ground by P.S.
cyl. conc. mons. 15x40 cm., Bearings grid: date of original sur. 4/23/78- 7/27/79: that of the
subd. Surv. 11/21/84- 4/20/85. Date approved 7/19/85.

A copy of Transfer Certificate of Title No. 12345 on file in Registry of Deeds of Taguig City,
which consists of 4 pages, is hereto attached as Annex “A” and made an integral part hereof;

3. That for taxation purposes, the parcel of land is covered by Declaration of Real
Property No. GL-020-07654 issued by the Office of the Assessor of Taguig City. It is bounded
on the northeast by Road Lot 24; on the southeast by Lot 14; on the southwest by Lot 12; and on
the northwest by Road Lot 22. A copy of Declaration of Real Property No. GL-020-07654 is
hereto attached as Annex “B” and made an integral part hereof;

4. That the names and addresses of the two (2) adjoining lot owners where they may be
served with notices are as follows :
4.1. Pedro Santos
Blk. 23, Lot 12, AFPVAI Phase 2, Western Bicutan, Taguig City

4.2. Jose Reyes

Blk. 22, Lot 15, AFPVAI Phase 2, Western Bicutan, Taguig City

5. That early this year, when petitioner was organizing his documents, he noticed that the
owner’s copy of Transfer Certificate of Title No. 12345 was missing. He exerted diligent and
earnest efforts to locate it, but it proved futile. He executed an Affidavit of Loss stating the fact
of loss of the certificate of title and have it recorded before the Registry of Deeds for Taguig
City. Copies of the Affidavit of Loss and Memorandum of Encumbrances issued by the Registry
of Deeds for Taguig City are attached hereto as Annexes “C” and “D” respectively and made
integral parts hereof;

6. That the owner’s duplicate of the Transfer Certificate of Title No. 12345 had not been
delivered to any person or entity to secure the payment or performance of any obligation
whatsoever, nor any transaction or document relating to the same is pending registration before
the Registry of Deeds for Taguig City;

7. That the original copy of Transfer Certificate of Title No. 12345 is still intact in the
office of the Registry of Deeds for Taguig City which could be the basis for the reissuance of a
new copy of the lost owner’s duplicate;

8. That the real property tax due on the property for the year 2020 had been paid by the
petitioner. Copy of the Certification issued by the Office of the City Treasurer of Taguig is
hereto attached as Annex “E” and made integral part hereof.

WHEREFORE, it is most respectfully prayed of this Honorable Court that judgment be

rendered:

1. Declaring the owner’s duplicate copy of Transfer Certificate of Title No. 12345 that
had been lost as null and void; and
2. Ordering the Registry of Deeds for Taguig City to issue a new owner’s duplicate copy
of Transfer Certificate of Title No. 12345, in the same terms and conditions as the
original thereof, upon payment of all the proper fees therefore.

Other reliefs just and equitable under the premises are likewise prayed for.
Batangas City for Taguig City, April 7, 2020.
_____________________
_____________________
Counsel for Petitioner
_____________________.,
____________________., Batangas City

By:

_____________________________
Roll No. _____________
 IBP No. _______________ Batangas City
PTR No. ___________________ Batangas City
MCLE Compliance No. _________
December 16, 2018

VERIFICATION AND CERTIFICATION

I, Juan De La Cruz, Filipino, of legal age, married and resident of Sabang, Lipa City,
Batangas, after having been sworn to in accordance with law, hereby deposed and state that:
1.That I am the petitioner in the above-entitled petition;
2. That I caused the preparation and filing of the foregoing petition and certifies that I
have read and understood the same and that the averments contained therein are true and correct
of my own knowledge and based on authentic documents;
3. That no other action or proceedings involving the same issues has been hereto
commenced any action/proceeding involving the matters/issues taken up in the present petition
with the Supreme Court/Court of Appeals/Regional Trial Court, or any other tribunal Court,
tribunal or agency other than this present petition, and if it should be learned later on that a
similar action or proceeding has been filed or is so pending, the undersigned undertakes to
report the fact within five (5) days therefrom to this Court.
Batangas City, _____________________.

JUAN DE LA CRUZ
Affiant
______________________

SUBSCRIBED AND SWORN to before me this _________________ at Batangas City,

affiant exhibiting to me his _______________________stated above.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2020