REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

THIRD (3RD) JUDICIAL REGION
Malolos City

IN RE: PETITION FOR THE

RECONSTITUTION OF LOST
OWNER’S DUPLICATE COPY
OF TRANSFER CERTIFICATE
OF TITLE NO. _____ ISSUED
BY THE REGISTER OF DEEDS
OF THE PROVINCE OF
BULACAN,
LRC CASE NO.
__________
___________,
Petitioner,

-versus-

REGISTER OF DEEDS OF THE

PROVINCE OF BULACAN,
Respondent.
x --------------------------------------- x

PETITION

COMES NOW PETITIONER _________, by and

through the undersigned counsel, and unto this Honorable

Court, most respectfully submits the instant Petition, and in

support thereof most courteously avers: That --

1. Petitioner is of legal age, Filipino and with postal

address at _______ where she may be served with notices,

orders, and other legal processes of this Honorable Court.

 2. Respondent REGISTER OF DEEDS OF THE

PROVINCE OF BULACAN (“respondent” for brevity) is the

provincial repository of certificates of title to real properties

registered under the Torrens system, among others, and is

located at Tabang, Guiguinto, Bulacan where it may be

served with summons, notices, orders, and other legal

processes of this Honorable Court.

3. Petitioner is the registered owner in fee simple of

a parcel of land situated in the Municipality of Calumpit,

Province of Bulacan and covered by Transfer Certificate Title

No. 137750 and more particularly described as follows, thus:

“Lot 16, Csd-031 107-00795-D

(AR) portion of Lot 957, Calumpit
Cadastral Location, Brgy. Sto. Niño,
Calumpit Bulacan. Boundaries SW ,
along line 1, lot 39, Csd-031407-
007951-D (AR) SW and NW., along lines
2-3-4 lot 38, Cad. 031407-007951-D
(AR) NE, along line 4-5 Road, NE and
SE. along lines 5-6-1 25, Csd -031407-
007951-D (AR). Beginning at pt.
marked “1” on plan being 61 deg. 32’E,
2045.01 m from PLJM#1, Calumpit
Cadastre; thence 1-2 N. 1 deg. 47’W.,
73.00 m. 2-3 N. 13 deg. 47’W., 115.44
m. 3-4 N.68 deg. 59’E.13 m. 4-5 S. 38
deg. 00’1. 86.03 m 5-6 S. 08 deg.
42’E., 114.04 m 6-1 S. 8 deg. 13’.,
38.61 m. Area; SEVEN THOUSAND
THREE HUNDRED TWENTY FIVE
2
 (7,325) SQUARE METERS. Bearings
true; date of orig. survey, May 31, 1979
date of subd. Plan September 4-5 1993.
Date Approved February 15, 1994,
description of corner by AR cyl. conc.
mons. 15 x 40 cms. x x x”

4. Petitioner is also the actual occupant and

possessor of the subject property.

5. The original copy of said TCT on file with

respondent had been lost or destroyed per certification of

said office, a copy of which is herewith attached and marked

as Annex “B” to form an integral part hereof.

6. Notwithstanding the loss of the original copy of

TCT on file with respondent, the original owner’s copy

thereof remains intact and extant, a copy of which is

herewith attached and marked as Annex “C” to form an

integral part hereof. The said original owner’s copy shall be

produced in court for comparative examination in the course

of the proceedings.

7. The property covered by said TCT is presently

mortgaged with International Exchange Bank only and to no

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other creditor or mortgagee.

5. The only improvement existing thereon are various

buildings likewise belonging to petitioner.

6. The lots directly adjoining the subject property on

the south, west and east side (Lots 25, 38 and 39, CSD-

031407-007951-D[AR]), are also owned, possessed and

occupied by petitioner, except for a road lot by the

northeastern boundary of the subject property that belongs

to the government.

7. There is no deed or instrument affecting the property

which has been presented for and/or pending registration to

this date in the office of respondent.

8. The original copy of the title on file with petitioner

may be availed of as basis for the reconstitution applied for.

PRAYER

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 WHEREFORE, it most respectfully prayed of this

Honorable Court that, after hearing and due proceedings, a

Resolution or Order be ISSUED:

1. Declaring null and void the Register of Deeds

duplicate copy of Transfer Certificate Title No.

137750 which had been lost; and

2. Directing the Register of Deeds of Quezon City,

after payment of the required fees, to issue in lieu

thereof, a new Register of Deeds duplicate which

shall in all respects be entitled to like faith and

credit as the original copy of Transfer Certificate

Title No. 137750.

OTHER RELIEFS, just and equitable under the

premises, are likewise most respectfully prayed for.

RESPECTFULLY SUBMITTED. Quezon City for

Malolos City, __ March 2014.

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 SCE Law
Attorneys-at-Law

SOLIVEN CASTILLO & ESCOBEDO

Law Offices

Unit 404 Tower A, The Regalia Park Towers

150 P. Tuazon Boulevard, Araneta Center
Cubao, Quezon City 1109
Tel. No: 425-75-13/Fax: 709-16-22
E-mail: scelo@lawyer.com

PETER S. CASTILLO II
Roll of Attorney No. 44374
PTR No: 1172741; 01.15.2014; Rizal
IBP No: 934161; 04.04.2013; RSM
MCLE Compliance No. IV-0013965;
03.27.2013

6
REPUBLIC OF THE PHILIPPINES)
____________________________) SS.

VERIFICATION AND CERTIFICATION AGAINST FORUM

SHOPPING

I, ____________, of legal age, Filipino, and with postal address

at ___________, after having been duly sworn to in accordance with
law, hereby depose and state: That--

1) I am the petitioner in the above-entitled case;

2) I have caused and ordered the preparation and filing of

the foregoing Petition and have read all the allegations contained
therein;

3) I hereby confirm and affirm that all the averments therein

are true and correct of my own knowledge and belief as well as
based on pertinent records and documents;

4) I hereby certify that petitioner has not filed nor initiated the
filing, and am not aware of any other complaint or action pending
before the Honorable Supreme Court, the Court of Appeals or any
other courts, boards or bodies and/or tribunals exercising judicial or
quasi-judicial functions, involving the same or similar causes/s of
actions; and

5) I further undertake that should I learn of the filing or

pendency of any such action before the Honorable Supreme Court,
the Court of Appeals or any other courts, boards or bodies and/or
tribunals exercising judicial or quasi-judicial functions, I shall inform
this Honorable Court of the same within five (5) days from knowledge
thereof.

IN WITNESS WHEREOF, we have hereunto set our hands this

__ day of March, 2014 in __________________.
th

____________

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 SUBSCRIBED AND SWORN to before me this __th day of
March, 2014 in ________________________; affiant exhibited to me
her ___________ issued on ________ at ______________.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2014.