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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


Third Judicial Region
Branch ___
Angeles City, Pampanga

IN RE: PETITION FOR ISSUANCE OF A NEW


OWNER’S DUPLICATE COPY OF TRANSFER
CERTIFICATE OF TITLE NO. 112656 WITH
CLOA NO. 00218400 REGISTERED IN THE
NAME OF RONALD G. ENRIQUEZ

RONALD G. ENRIQUEZ,
Petitioner,
LRC CASE NO. _______
-versus-

REGISTER OF DEEDS FOR ANGELES CITY,


PROVINCIAL AGRARIAN REFORM PROGRAM
OFFICER OF PAMPANGA, and all persons that
may be affected thereby,
Respondents.

x----------------------------------------------------------------x

PETITION

COMES NOW, herein petitioner RONALD G. ENRIQUEZ, through


the undersigned counsel, and unto this Honorable Court most
respectfully states and avers that:

1. Petitioner RONALD G. ENRIQUEZ is of legal age, Filipino, married,


and a resident of Brgy. Planas, Porac, Pampanga, where he may be
served with summons, pleadings, and other legal processes of this
Honorable Court. He may also be contacted at
+639_________________;

2. Public Respondent Register of Deeds for Angeles City is impleaded


being the government agency tasked with the registration of titles
and deeds within Porac, Pampanga. It holds office at LRA Building,
City Hall Compound, Pulung Maragul, Angeles City, Pampanga,
where it may be served with summons, pleadings, and other legal
processes of this Honorable Court;

3. Public Respondent Provincial Agrarian Reform Program Officer of


Pampanga is impleaded being the head of the government agency
tasked with the issuance of titles of under the Comprehensive
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Agrarian Reform Program of the government within Pampanga. It
holds office at Millet’s Arcade, R&E Building, Brgy. Del Pilar, City
of San Fernando, Pampanga where it may be served with
summons, pleadings, and other legal processes of this Honorable
Court;

4. Petitioner is the registered owner of the parcel of land covered by


Transfer Certificate of Title (TCT) No. 112656 with Certificate of
Land Ownership Award (CLOA) No. 00218400 located at Planas,
Porac, Pampanga, with an area of Twelve Thousand One Hundred
Fourteen (12, 114) square meters, more or less;

5. Petitioner has been in possession of the original Owner’s


Duplicate Copy (ODC) of the above-mentioned Title since it was
issued on September 2, 1983;

6. However, sometime from October 26, 2020 to November 6, 2020,


when petitioner was trying to secure a loan/mortgage over the
subject property, he brought with him the brown envelope
containing the Owner’s Duplicate Copy of TCT No. 112656 with
CLOA No. 00218400;

7. While commuting, petitioner Enriquez fell asleep. When he woke


up, he noticed that the brown envelope containing the Owner’s
Duplicate Copy of TCT No. 112656 with CLOA No. 00218400 was
gone and missing;

8. Petitioner Enriquez tried to look for the envelope by tracing back


his commute, but he was not able to retrieve the brown envelope
containing the Owner’s Duplicate Copy of TCT No. 112656 with
CLOA No. 00218400;

9. After exhausting all possible remedies and exerting diligent


efforts in finding the ODC and the same remaining unsuccessful,
petitioner Enriquez have acceded to the fact that the ODC of TCT
No. 112656 with CLOA No. 00218400 is now lost;

10. To support the fact that the ODC of TCT No. 112656 with CLOA
No. 00218400 has been lost, petitioner Enriquez executed an
Affidavit of Loss;

11. The same Affidavit of Loss has been annotated at the back of the
copy of TCT No. 112656 with CLOA No. 00218400 with the file of
the Register of Deeds for Angeles City;

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12. Petitioner confirms that the landholding covered by TCT No. TCT
No. 112656 with CLOA No. 00218400 is not mortgaged, sold,
conveyed, disposed of, or encumbered to any person or entity.
Further, herein petitioner certifies and confirms that the ODC was
never confiscated nor relinquished in favor of any government
entity, agency, or authority;

13. The original copy of TCT No. 112656 with CLOA No. 00218400 is
intact and existing in the files of the Register of Deeds of
Pampanga.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable


Court that after due notice and hearing, an ORDER be issued ordering
the Register of Deeds for Angeles City to generate and issue a new
owner’s duplicate copy of TCT No. TCT No. 112656 with CLOA No.
00218400 registered in the name of the Petitioner Ronald G. Enriquez
and thereafter register the same in lieu of the lost original owner’s
duplicate copy of the said title.

Other reliefs just and equitable under the premises are likewise
prayed for.

Angeles City, Pampanga. February ___, 2021

ATTY. JUSTIN L. ELIZAGA


Counsel for the Petitioner
Unit 2A, CSC Building 109 McArthur Highway
Brgy. Sto. Cristo, Angeles City 2009 Pampanga
ROLL NO. 68286
IBP LIFETIME NO. 16265
PTR NO. AC-1594836 / Angeles City / December 02, 2020
MCLE VI-0006585
E-mail address: jle.cdelaw@gmail.com
Mobile No. 0917-3770113

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Exhibit “A” – Order of the Court giving due course to the petition
Exhibit “B” – Certificate of Posting
Exhibit “C” – Electronic Copy of TCT No. 112656 with CLOA No.
00218400
Exhibit “D” – Tax Declaration of TCT No. 112656 with CLOA No.
00218400
Exhibit “D-1” – Tax Clearance of TCT No. 112656 with CLOA No.
00218400
Exhibit “E” – Affidavit of Loss

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