Republic of the Philippines

REGIONAL TRIAL COURT

______ Judicial Region
BRANCH ____
Lipa Batangas

In the Matter of Reissuance of

the New Owner’s Duplicate of LRC Case No. ___________
Certificate of Title No. T-12345. FOR: Reissuance

Kulasa dela Cruz,

Petitioner,

-versus-

Register of Deeds of Batangas,

Respondent,
x ----------------------------------- x

PETITION

Petitioner, through counsel, unto the Honorable Court, most respectfully states
that:

1. Petitioner is of legal age, Filipino and a resident of 2 Sabang, Lipa City;

2. Respondent Register of Deeds of Batangas is a duly constituted officer of the

Republic of the Philippines and may be served with summons and other court
processes in its office at Tolentino Road, Kumintang Ibaba,, 4200 Batangas City,
Philippines.

3. The Register of Deeds of Abra is impleaded herein as respondent for being the
officer charged with the issuance and safekeeping of certificates of titles of real
properties in Batangas.

4. Matilda Santos, Petitioner’s mother, donated to her a parcel of land together with
all improvements thereon covered by Transfer Certificate of Title No. T-12345 of
the Registry of Deeds for the Province of Batangas, containing an area of Four
Thousand Nine Hundred Sixty Eight (4,968) square meters, and more particularly
described as follows:

“A parcel of land [ Lot 8576’Batangas Cadastre’ (LRC) SW-9651’ Cad.

Rec. Bk. 61) situated in the Municipality of SanJose, Island of Luzon.
Bounded on the NE., points 7 to 1 by Lot 8575, Batangas Cadastre,
and points 1 to 2, by Lot 8569, Batangas Cadastre; on the SE. points 2
to 3 by Lot 8569, Batangas Cadastre; on the SW. points 3 to 5 by creek;
on the NW., points 5 to 7, by Lot 8577, Batangas Cadastre. Beginning
at a point marked “1 on the plan being N. 61 deg. 17’ E., 778.16 m from
 BBM 62, Lipa Cadastre; THENCE S. 18 deg.01’ E., 27.62 m. to point 2
; S. 64. deg. 05’ W., 56.66 m to point 3; N. 48 deg. 49’ W., 36.70 m to
point 4; N. 48 deg 58’ W., 30.00 m to point 5; N. 54 deg. 56’ E., 3.50
m. to point 6; N. 54 deg. 57’ E., 60.13 m. to point 7; S. 30 deg. 35’ E.,
47.63 m. to the point of beginning; containing an area of FOUR
THOUSAND NINE HUNDRED AND SIXTY EIGHT (4, 968)
SQUARE METERS, more or less.”

5. That the said donation is evidenced by a Deed of Donation docketed as Doc. No.
1; Page No. 2; Book No. X; Series of 2020; in the Notarial Register of Notary Public
Jose Ilagan, a copy is attached hereto as Annex “A”;

6. That after the execution of the Deed of Donation, the donor delivered to Petitioner
the possession the copy of the Owner’s Duplicate of the Transfer Certificate of Title
No. 12345;

7. That recently, Petitioner, in the process of transferring to her name the certificate
of title, discovered that the Owner’s Duplicate of the Transfer Certificate of Title
No. T-12345, which was delivered to her by the donor, is missing from her personal
documents and records;

8. That she exerted earnest efforts to locate the Owner’s Duplicate of the Transfer
Certificate of Title No. T-12345, but it proves futile and which she considered it
lost already;

9. That the Owner’s Duplicate of the Transfer Certificate of Title No. T-12345 is not
the object of any mortgage, and is not delivered to any person, natural or juridical,
to secure any debt or obligation;

WHEREFORE, PREMISES CONSIDERED, Petitioner, through counsel, most

respectfully pray that after notice and hearing, this Honorable Court renders
judgment:

a. Declaring the owner’s duplicate copy of OCT No. T-12345 lost and thus null
and void; and
b. Ordering the Register of Deeds of Batangas to issue a new owner’s duplicate
copy of OCT No. T-12345 in lieu of the lost one under the same terms and
conditions.
Other reliefs just and equitable in the premises are likewise prayed for.

Lipa City, 02 December 2022.

BENJAMIN LUKE PHILLIP G. VERDADERO

Counsel for Petitioner
Roll of Attorneys No. 12345
IBP No. 123456
PTR No. 1234567 / January 03, 2023
MCLE Compliance No. VII-1234567 / April 06, 2023
Email address: lukeverdadero@gmail.com