Republic of the Philippines

REGIONAL TRIAL COURT

Fourth Judicial Region
Justice Hall, Santa Monica
Puerto Princesa City

PETITION FOR CORRECTION OF

ENTRY IN THE AREA OF LOT NO.
13224, CAD 796-D, C-24, COVERED
BY OCT NO. C-2949, WITH CLOA
NO. 00097768, ISSUED IN THE
NAME OF MERCEDES S.
SUCALDITO, ET AL.

DEPARTMENT OF AGRARIAN
REFORM, PROVINCE OF
PALAWAN, represented by
Provincial Agrarian Reform
Program Officer II, CONRADO S.
GUEVARRA, and the Agrarian
Reform Beneficiaries; MERCEDES S.
SUCALDITO, GLORIA S. MOLE,
ADRESITO S. SUCALDITO and
MYRNA S. SUCALDITO
Petitioner,

- versus - CASE NO.____________

For Correction of Entry under
Section 108, P.D. 1529

THE REGISTER OF DEEDS,

PROVINCE OF PALAWAN,
Respondent.
X- - - - - - - - - - - - - - - - - - - - X

P E T I T I O N

PETITIONER, by counsel, unto to the Honorable Court,

respectfully state/s;

1. That petitioner, CONRADO S. GUEVARRA, as the

Provincial Agrarian Reform Program Officer of the Department of
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Agrarian Reform Palawan, is in charge of the implementation of the

Comprehensive Agrarian Reform Program of the government in the
Province of Palawan and in the City of Puerto Princesa. He may be
served with summons and other processes of the Honorable Court at
Second Floor, Ednel’s Building, No. 62 Manalo Street, Barangay
Masipag, Puerto Princesa City;

2. That public respondent, the Register of Deeds of Province

of Palawan is the government agency mandated to execute the laws
relative to the registration of lands particularly Presidential Decree
No. 1529 and other related laws in the Province of Palawan and may
be served with summons and other processes of the Honorable Court
at Ground Floor, Provincial Capitol Building, Fernandez Street,
Barangay Tanglaw, Puerto Princesa City;

3. That MERCEDES S. SUCALDITO, GLORIA S. MOLE,

ADRESITO S. SUCALDITO and MYRNA S. SUCALDITO, are co-owners
and farmer beneficiaries of a parcel of land, identified as Lot No.
13224, Cad 796-D, C-24, with an area of 104,187 square meters, more
or less, located at Barangay Labog, Sofronio Española, Palawan,
covered by OCT No. C-2949, with CLOA No. 00097768, registered
before the Registry of Deeds of Palawan on August 26, 1994. The
electronic copy of OCT No. C-2949, with CLOA No. 00097768, is
hereto attached as Exhibit “1”;

4. Sometime in March 1996, the registered co-owners;

MERCEDES S. SUCALDITO, GLORIA S. MOLE, ADRESITO S. SUCALDITO
and MYRNA S. SUCALDITO, sought to end the co-ownership on Lot
13224, Cad 796-D, C-24, covered by OCT No. C-2949, and to have a
separate and individual title/CLOA in their respective names.
Therefore, Lot No. 13224, Cad 796-D, C-24, with an area of 104,187
square meters, more or less, was surveyed and subdivided into FOUR
(4) lots under Subdivision No. Psd-04-093285(AR), approved on
August 26, 1996, by Elpidio P. Tolentino, OIC Regional Technical
Director, DENR, LMS, Region IV-B, Manila, delineating and allocating
their respective lots with corresponding area wherein the aggregate
area of the resulting FOUR (4) lots is 104,187 square meters, to wit:

Name of Farmer Lot Nos. Area (Sq. Ms.)

Beneficiaries
MERCEDES S. LOT 13224-A 27,418
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SUCALDITO
GLORIA S. MOLE LOT 13224-B 9,139
ADRESITO S. SUCALDITO LOT 13224-C 9,139
MYRNA S. SUCALDITO LOT 13224-D 9,139
Total: 104,187

A copy of the Approved Subdivision Plan No. Psd-04-

093285(AR) is hereto attached as Exhibit “2”;

7. Scrutiny and verification of the documents at hand, it can

be clearly seen that the area written in the OCT No. C-2949, with
CLOA No. 00097768, differs from that of the Approved Subdivision
Plan No. Psd-04-093285(AR), of Lot 13224, Cad 796-D, C-24. The
correct and exact area of Lot 13224, Cad 796-D, C-2949 is 54,830
square meters as stated in the approved subdivision plan and not
104,187 square meters written in the first page and in Page A of OCT
No. C-2949. To show proof that indeed the true and correct area of
Lot 13224, Cad 796-D, C-24, is 54,830 square meters and not
104,187 square meters, Andres L. Valencia, OIC Chief of Regional
Surveys Division, DENR, LMS, Region IV-B, Manila, had signed a
Certification written and appearing in the lower left portion of the
Approved Subdivision (Exhibit “2” of the instant petition) which was
highlighted for easy reference of the Honorable Court and quoted
hereunder:

CERTIFICATION

I hereby certify that the bearings

and distances of the boundary lines of
the land are identical to those
described in OCT No. E-11899 as
certified by the Register of Deeds
except the correct area should be
42,246 sq.m. instead of 42,237 sq.m. as
appearing in the title.

8. In addition, to further show that indeed there is error in

the area in OCT No. C-2949, attached as Exhibit “3” is the original
copy of the Certification dated _______, issued by Conrado S. Guevarra,
Provincial Agrarian Reform Program Officer II of DAR-Palawan,
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certifying as to the correct area corresponding to Lot No. 13224, Cad

796-D, C-24, covered by OCT No. C-2949.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed to the Honorable Court that after due notice and hearing,
judgment be issued:

1. Declaring the area in Lot 13224, Cad 796-D, C-24,

inscribed in the first page and in Page A of OCT No. C-2949, with
CLOA No. 00097768, issued in the names of MERCEDES S.
SUCALDITO, ET AL. equal to 54,830 square meters based on the
Approved Subdivision Plan No. Psd-04-093285(AR);
2. Ordering the Register of Deeds of Palawan to cause the
correction of the area in Lot 13224, Cad 796-D, C-24, inscribed in the
first page and in Page A in OCT No. C-2949, with CLOA No. 00097768
from 104,187 square meters to 54,830 square meters based on
Approved Subdivision Plan No. Psd-04-093285(AR), issued in favor of
Mercedes S. Sucaldito, et al; and

3. Ordering the Register of Deeds of Palawan to issue a new

certificate of title containing the corrected area of Lot 13224, Cad
796-D, C-24, covered by OCT No. C-2949 with CLOA No. 00097768.

Other relief and remedy just and equitable under the premises
are likewise prayed for.

___________________, _________________, 2023.

__________________________
Petitioner

VERIFICATION AND CERTIFICATION

OF NON-FORUM SHOPPING

I, _____________________, Filipino, of legal age, and residents of

___________________________, after having been duly sworn to in
accordance with law, do hereby depose and state that:

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

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2. I have caused the preparation and filing of the foregoing

petition;

3. I have read the contents of the foregoing petition and I

attest that the same are true and correct based on records in
our possession;

4. I further certify that I have not commenced any other

action or proceeding involving the same issues subject of this present
petition in the Supreme Court, the Court of Appeals, or the different
Divisions thereof, or any other tribunal or agency and in the event
that petitioners hereafter learn that a similar action or proceeding has
been filed or is pending before the Supreme Court, the Court of
Appeals, or the different Divisions thereof, or any other tribunal or
agency, petitioners undertake to promptly inform this Honorable
Adjudicator of that fact within five (5) days from notice.

FURTHER, I SAY NAUGHT.

______________________

SUBSCRIBED AND SWORN to before me this ___ day of

____________ 2023, in______________________, affiants exhibited to me
their valid proof of identifications indicated below their names.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2023