Republic of the Philippines

REGIONAL TRIAL COURT

1st Judicial Region
BRANCH 27
City of San Fernando, La Union

PETITION FOR THE REGISTRATION

OF UNREGISTERED LAND LOCATED
AT SAGAYAD, CITY OF SAN FERNANDO, LA UNION

LAND REGISTRATION
CASE NO. 1027
POGI N. CIATALAGA,
Petitioner,
-versus-

THE REGISTER OF DEEDS OF LA UNION,

Respondent

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PETITIO N
PETITIONER, by and through counsel, unto this Honorable Court respectfully aver
that:

1. Petitioner, POGI N. CIATALAGA, is of legal age, single, Filipino citizen and a

resident of Purok 3, Cadaclan, City of San Fernando, La Union;

2. Respondent is the Register of Deeds of La Union which has an official address at

Government Center, Sevilla, City of San Fernando, La Union, where it may be
served with summons and other court processes at the given address;

3. Petitioner is applying for the registration of the unregistered land located at parcel of
land located at Sagayad, City of San Fernando, La Union, more particularly
described as follows:

TAX DECLARATION NO. 21-055-103557

“A parcel of land conaining an area of TWO HUNDRED (200) SQUARE

METERES, more or less; situated at Sagayad, City of San Fernando, La Union;
designated as Lot No. 1234; Assessed at Php 2,000.00: Boundaries: North – Lot No. 5678;
East: Lot No. 9101; South – Lot No. 1213; West: Lot No. 1415.”

4. That petitioner has acquired the subject real property by virtue of a Deed of Absolute
Sale executed between him and Ms. Maganda C. Ako on April 20, 2022 who her
predecessors-in-interest has been on open, peaceful, continuous, uninterrupted
possession in the concept of an owner of the subjectproperty since time immemorial;

5. That the subject property is presently unoccupied, and the adjoining real properties
thereon, which are the following:
a. Ms. Leni Robredo, Lot No. 5678, Sagayad, City of San Fernando, La Union
 b. Mr. Bong-Bong Marcos, Lot No. 9101, Sagayad, City of San Fernando, La
Union
c. Mr. Ping Lacson, Lot No. 1213, Sagayad, City of San Fernando, La Union
c. Mr. Manny Pacquiao, Lot No. 1425, Sagayad, City of San Fernando, La
Union

6. That to the best of petitioner’s knowledge and belief, there is no mortgage or

encumbrance of any kind whatsoever affecting said land, nor any other person
having any interest therein, legal or equitable; and

7. That the following documents are attached and made a part of this petition: (a) Deed
of Absolute Sale dated April 20, 2022; (b) SurveyPlan duly approved by the Director
of Lands; (c) Surveyor’s Certificate and Technical Description; (d) Tax Assessment
Certificate; and (e) Sworn Statements of Ms. Maganda C. Ako and Pogi C. Ciatalaga.

PRAYER
WHEREFORE, it is respectfully prayed that the Register of Deeds of La Union issue an
original certificate of title of the lot located at Sagayad, City of San Fernando, La Union
registered in the name of the petitioner. Other just and equitable reliefs are likewise prayed for.

22nd day of April 2022, City of San Fernando, La Union, Philippines.

Sgd.
ATTY. ELYN D. APIADO
Notary Public – La Union – Until Dec. 31, 2022
Notarial Commission Serial No. 27- 2021
Attorney’s Roll No. 102797, October 27, 2014
IBP Lifetime No. 092095, September 20, 2015
PTR No. 5478421, January 03, 2021 – La Union
APIADO LAW OFFICE
1st Flr., Apiado Bldg., Sagayad, CSFLU

VERIFICATION AND CERTIFICATION

Republic of the Philippines )
Province of La Union ) S.C.
City of San Fernando, La Union )

I, POGI N. CIATALAGA, of legal age, single, Filipino Citizen, after having been duly
sworn in accordance with law, depose and state that:

1. I am the petitioner/applicant in the above-stated case;

2. I caused the preparation of the foregoing petition;

 3. I have read the contents thereof and the facts stated therein are true and correct of my
personal knowledge and/or on the basis of copies of documents and records in my
possession;

4. I have not commenced any other action or proceeding involving the same issues in
the Supreme Court, the Court of Appeals, or any other tribunal or agency;

5. To the best of my knowledge and belief, no such action or proceeding is pending in

the Supreme Court, the Court of Appeals, or any other tribunal or agency;

6. If I should thereafter learn that a similar action or proceeding has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other tribunal or
agency, I undertake to report that fact within five (5) days therefrom to this
Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 22nd day of

April, 2022 at City of San Fernando, La Union, Philippines.

Sgd.
POGI N. CIATALAGA
Affiant

SUBSCRIBED AND SWORN to before me this 22nd day of April 2022 at City of San
Fernando, La Union, Philippines affiant exhibiting to me his Community Tax Certificate No.
02457635 issued on September 20, 2012 at City of San Fernando, La Union, Philippines.

Sgd.
ATTY. ELYN D. APIADO
Notary Public – La Union – Until Dec. 31, 2022
Notarial Commission Serial No. 27- 2021
Doc. No. 10; Attorney’s Roll No. 102797, October 27, 2014
Page No. 27; IBP Lifetime No. 092095, September 20, 2015
Book No. III`; PTR No. 5478421, January 03, 2021 – La Union
Series of 2022 APIADO LAW OFFICE
1st Flr., Apiado Bldg., Sagayad, CSFLU