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Petition for Duplicate TCT Issuance

1) Cecilia Baluyot Flores filed a petition for the issuance of a new owner's duplicate title in lieu of the lost original title. 2) Flores needs to testify regarding the circumstances of the lost title but she is scheduled to return to the United States on April 23. 3) Her counsel filed a motion requesting that Flores' testimony be taken by deposition before the Branch Clerk of Court on April 18, 19 or 20 before she leaves the country.

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50 views3 pages

Petition for Duplicate TCT Issuance

1) Cecilia Baluyot Flores filed a petition for the issuance of a new owner's duplicate title in lieu of the lost original title. 2) Flores needs to testify regarding the circumstances of the lost title but she is scheduled to return to the United States on April 23. 3) Her counsel filed a motion requesting that Flores' testimony be taken by deposition before the Branch Clerk of Court on April 18, 19 or 20 before she leaves the country.

Uploaded by

Tazurc Tom
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


THIRD JUDICIAL REGION
BRANCH 3, BALANGA CITY

PETITION FOR ISSUANCE OF


NEW OWNER’S DUPLICATE
OF TCT NO. T-2426 IN LIEU
OF ONE LOST

CECILIA BALUYOT FLORES,


Petitioner,
vs. CAD. CASE NO. 3240-23

TEODORA TRINIDAD AND THE


REGISTER OF DEEDS
FOR BATAAN,
Respondent.
x------------------------------------------x

MOTION FOR LEAVE


TO TAKE DEPOSITION

Petitioner, by counsel, avers:

1. Petitioner is a permanent resident of the United


States and is currently in the Philippines for a vacation.

2. Petitioner is scheduled to return to the United Sates


on April 23, 2023. Copy of her flight details is attached as
Annex A.

3. The Affidavit of Loss in this petition was executed by


petitioner. Thus, it is only petitioner who can testify on the
circumstances of the loss of the subject title.

4. In view of the foregoing, petitioner moves that her


testimony be taken by deposition upon oral examination
before the Branch Clerk of Court on April 18, 19 or 20, 2023.
PRAYER

WHEREFORE, it is respectfully prayed of the Honorable


Court that the testimony of the petitioner be taken by deposition
upon oral examination before the Branch Clerk of Court. 

Other reliefs just and equitable are likewise prayed for.

Balanga City, April 17, 2023.

VINCENT EMMANUEL T. CRUZ


Counsel for the Petitioner
Ground Floor Bataan People’s Center
Capitol Compound, Balanga City
09199963074/vinzcruz@gmail.com
PTR No. 3377096; Balanga City; 01/04/23
IBP No. 275023; Bataan; 01/07/23
MCLE Compliance No. VII-0001751; 12/3/19
Roll No. 49679

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