REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

First Judicial Region
Branch 20
Vigan City, Ilocos Sur

IN THE MATTER OF THE

REISSUANCE OF ANOTHER
OWNER’S DUPLICATE COPY
OF KATIBAYAN NG
ORIHINAL NA TITULO BLG.

HEIRS OF REMEDIOS
RABANG APDAL, namely:
ROWENA APDAL MARANETA,
CALVIN R. APDAL, RUBIA
CATALINA R. APDAL-
LRC Admin. Case No.
VILLAMIN, and TIFFANY
189-22
APDAL SAN DIEGO,
represented by their
attorney-in-fact,
BERNADETTE PLANA,
Petitioners,
-versus-

OFFICE OF THE REGISTRY

OF DEEDS FOR THE
PROVINCE OF ILOCOS
SUR
Respondent.
x---------------------------------x
FORMAL OFFER OF EXHIBITS / EVIDENCE

PETITIONERS, by the undersigned counsel and unto this

Honorable Court, most respectfully offer and adopt the
following documentary exhibits/evidence:

1. Exhibit “A and series” - Special Power of

Attorney executed by Rowena Apdal Maraneta - To
prove that Bernadette Plana is duly authorized to
file the instant Petition and to adduce evidence in
her behalf;
 FORMAL OFFER OF EXHIBITS/EVIDENCE|2

2. Exhibit “B and series” - Special Power of

Attorney executed by Calvin Rabang Apdal - To
prove that Bernadette Plana is duly authorized to
file the instant Petition and to adduce evidence in
his behalf;

3. Exhibit “C and series” - Special Power of

Attorney executed by Rubia Catalina R. Apdal
Villamin - To prove that Bernadette Plana is duly
authorized to file the instant Petition and to adduce
evidence in her behalf;

4. Exhibit “D and series” - Special Power of

Attorney executed by Tiffany Apdal San Diego - To
prove that Bernadette Plana is duly authorized to
file the instant Petition and to adduce evidence in
her behalf;

5. Exhibit “E” - Birth Certificate of Rowena Apdal

Maraneta - To prove her relationship with the
registered owner and to further prove her legal
interest over the parcel of land covered by KOT Blg.
P-37315;

6. Exhibit “F” - Birth Certificate of Calvin Apdal - To

prove his relationship with the registered owner and
to further prove his legal interest over the parcel of
land covered by KOT Blg. P-37315;

7. Exhibit “G” - Birth Certificate of Rubia Catalina

Apdal Villamin - To prove her relationship with the
registered owner and to further prove her legal
interest over the parcel of land covered by KOT Blg.
P-37315;

8. Exhibit “H” - Birth Certificate of Tiffany Apdal San

Diego - To prove her relationship with the
registered owner and to further prove her legal
interest over the parcel of land covered by KOT Blg.
P-37315;

9. Exhibit “I and series” - Electronic copy of

Katibayan ng Orihinal na Titulo Blg. P-37315 - To
prove the existence of the owner’s duplicate copy of
the said certificate of title and to further prove the
 FORMAL OFFER OF EXHIBITS/EVIDENCE|3

identity of the registered owner of the property

covered by said certificate of title;

10. Exhibit “J and series” - Death Certificate of

Remedios Rabang Apdal - To prove the fact of
death of the registered owner and mother of the
petitioners;

11. Exhibit “K and series” - Death Certificate of

Crescencio Apdal - To prove the fact of death of the
husband of the registered owner and father of the
petitioners;

12. Exhibit “L” - Affidavit of Loss - To prove the fact of

loss of the owner’s duplicate copy of KOT Blg. P-
37315;

13. Exhibit “M” – Notice of Hearing – to prove that all

persons interested in the re-issuance of the owner’s
duplicate copy of KOT Blg. P-37315 was properly
notified, to show cause why the petition should be
granted and to prove compliance with the
jurisdictional requirements;

14. Exhibit “N” – Certificate of Posting – to prove the

fact that copies of the notice of hearing and the
petition were posted in at least three (3)
conspicuous places where the property is situated
and to further prove compliance with the
jurisdictional requirements;

15. Exhibit “O and series” – Registry Receipt and

Registry Return Card – to prove that Defendant was
proper notified, to prove that Defendant received a
copy of the petition and to prove compliance with
the jurisdictional requirements; and,

16. Exhibit “P” – Acknowledgement Receipt of the

Office of the Provincial Prosecutor – to prove that
the Office of the Provincial Prosecutor of Ilocos Sur
received a copy of the petition and to prove
compliance with the jurisdictional requirements.
 FORMAL OFFER OF EXHIBITS/EVIDENCE|4

All of the original copies of the abovementioned

exhibits/documentary evidence of Petitioners were previously
submitted to the Honorable Court.

PRAYER

WHEREFORE, it is most respectfully prayed of this

Honorable Court that the aforementioned
exhibits/documentary evidence of Petitioners be admitted.

Other just and equitable reliefs are likewise prayed for.

RESPECTFULLY SUBMITTED.

Bantay for Vigan City, Ilocos Sur. July 1, 2022.

ATTY. LEX VINCENT P. DAGDAG

Counsel for Petitioners
Roll No. 74722 | 07/15/2020
IBP O.R. No. 183596 | 01/03/2022 | Pasig City
PTR No. 5769528| 1/03/2022 | Ilocos Sur
TIN: 420-785-402-000
MCLE No. VII-0004209 | 04/14/2025
Main Office: Amante St., Zone 5,
Bantay, 2727, Ilocos Sur, Philippines
Sub-Office:2F, Bantay Arcade, Zone 6,
Bantay, 2727, Ilocos Sur, Philippines,
atty.lexdagdag@gmail.com | +639392498459

COPY FURNISHED THROUGH REGISTERED MAIL WITH

RETURN CARD AND ELECTRONIC MAIL TO:

OFFICE OF THE PROVINCIAL PROSECUTOR

Vigan City, Ilocos Sur, Philippines