Sie sind auf Seite 1von 3

Republic of the Philippines

REGIONAL TRIAL COURT


FIRST JUDICIAL REGION
Branch 69
Dagupan City

IN RE: PETITION FOR


ISSUANCE OF A NEW TITLE
IN LIEU OF THE LOST ONE

Sp. Civil Case no.6969

Raul Vicente C. Campos


Petitioner,

- vs -

The Register of Deeds of Dagupan City


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

PETITION

The Petitioner through Counsel and unto this Honorable Court respectfully, states;

1.) That petitioner is of legal age, single, and a resident of 26th Amado street, Tapuac
District, Dagupan City;
2.) That respondent is likewise of legal age, married, with office address at __________
where he may be served with summons;
3.) That respondent is being included merely as a nominal party, being the public officer
responsible for the issuance of a new title sought for in this petition;
4.) That petitioner is the registered owner of a parcel of land covered by TCT No
69696969696969, and particularly described as follows:

“ A parcel of Land situated in Lucao Dagupan City (Cad. No. 123456) bounded on
the north by ______;
on the south by _______;
on the east by ________;
on the west by ________;

Containing an area of 2000 sq. meter more or less, and assessed at P69, 000,000”

5.) That the court’s copy of the title of the above described land was kept by the
petitioner and that he placed the same inside a cabinet in his bedroom in his residence
in Amado Street, Tapuac District, Dagupan City;
6.) That sometime the petitioner’s residential house was burned due to faulty electrical
wirings;
- 2 -

7.) That among the documents completely damaged during the conflagration was the title
of the afore described land;
8.) That the said title could no longer be located and is considered lost beyond recovery,
thus this petition;
9.) That petitioner secured a copy of the title in the custody of the respondent register of
deeds, copy of which is attached as annex A hereof to show that the copy of the title
with the register of deeds is intact;
10.) That petitioner notified the respondent the respondent Register of Deeds about the
fact of loss of the owner’s copy of the title as shown by the petitioner’s affidavit of
loss, attached as annex B hereof and the notice of loss served to the Register of
Deeds, copy of which is attached as annex C hereof;

WHEREFORE it is respectfully prayed that an order be issued directing the respondent


Register of Deeds to issue a new owner’s copy of TCT no. 69696969696969 in liu of the
lost one.

Other reliefs just and equitable are likewise prayed for.

Dagupan City, February 10, 2018

ATTY. ERIC C. CAMPOS


Counsel for Petitioner
PTC No. 123
Roll No. 456
MCLE Compliance

VERIFICATION AND CERTIFICATION


OF
NON-FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES


Dagupan City, Province of Pangasinan } SS.

Raul Vicente C. Campos, after being duly sworn, deposes and says that he is the
plaintiff in the above entitled case; that he has read the above attached pleading, and that the
allegations therein are true of his own knowledge.

Raul Vicente C. Campos


Affiant
- 3 -

SUBSCRIBED and sworn to before me in Dagupan City, Province of Pangasinan,


Philippines, this 10th day of February, 2018, Affiant having exhibited to me his Residence Tax
Certificate No. 69, issued at Dagupan City on the 10th day of January, 2018.

Atty. Shabalaba Ding Dong


NOTARY PUBLIC

Das könnte Ihnen auch gefallen