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ANNULMENT AND/OR
DECLARATION OF NULLITY
OF: (A)
PETITION/APPLICATION FOR
EXTRA-JUDICIAL
FORECLOUSE UPON
TRANSFER CERTIFICATE OF
TITLE NO. T-12345 OF THE
REGISTRY OF DEEDS FOR
QUEZON CITY; (B) REAL
ESTATE MORTGAGE; (C)
NOTICE OF SHERIFF SALE;
(D) AFFIDAVIT OF
PUBLICATION; (E)
CERTIFICATE OF POSTING;
(F) CERTIFICATE OF RAFFLE;
(G) MINUTES OF AUCTION
SALE; (H) BID; (I)
CERTIFICATE OF SALE; (J)
AFFIDAVIT OF
CONSOLIDATION OF TITLE;
and (J) TRANSFER
CERTIFICATE OF TITLE NO.
T-45678
-versus-
x-----------------------------------------x
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COMPLAINT
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however, it informed him that his remedy to secure a
replacement for a loss title is to file a petition with the Court;
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13. The Defendant banks did not notice that the
identification cards presented to them by the impostor were
all falsities, all apparent on the face, and that the said
impostor is not the true owner of the Duplicate Certificate of
Title used as a collateral for the Real Estate Mortgage;
17. That the mortgagor, Erickson Luz, not being the true
owner of the subject property, cannot exercise any right of
ownership over the property; he cannot alienate nor can he
encumber it by constituting a Real Estate Mortgage, offering
it as a collateral; and
PRAYER
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corresponding notice of sheriff sale, affidavit of publication,
certificate of posting, certificate of raffle, minutes of auction
sale, bid, certificate of sale, and affidavit of consolidation of
title;
By:
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VERIFICATION/ CERTIFICATION
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Roll Number 99999
IBP No. 78000001 dated 03.30.12
MCLE NO. IV-333333 dated 03.30.12
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