Republic of the Philippines

NATIONAL CAPITAL REGION

Regional Trial Court
Branch ____
OFFICE OF THE CLERK OF COURT & EX-OFFICIO SHERIFF
PROVINCE OF BATANGAS

IN RE: PETITION FOR EXTRAJUDICIAL FORECLOSURE

OF REAL ESTATE MORTGAGE UNDER ACT NO.
3135, As amended

Case No.______

CHERYL LIM-CORDOVA
Petitioner-Mortgagee,

versus

AMELIA B. ROBERTS
Mortgagor-Debtor.

x_________________________________x

PETITION FOR EXTRAJUDICIAL FORECLOSURE OF REAL ESTATE

MORTGAGE

THE CLERK OF COURT

TANUAN CITY

Sir/Madam:

Greetings!

The petitioner-mortgagee, CHERYL LIM-CORDOVA, is married, of

legal age, Filipino citizen and residing at Pio Del Pilar, Makati City, most
respectfully alleges:

1. That on January 8, 2016, the mortgagor, AMELIA B. ROBERTS,

widow, of legal age, Filipino citizen and resident of Wack-Wack
 Greenhills, Mandaluyong City, executed a contract of real estate
mortgage in my favor which is attached hereto as annex “A”
wherein he mortgaged her property to secure her debt;

2. That the loan of the mortgagor-debtor is evidenced by the

promissory note and the same is attached as annex “B”;

3. That to the best of my knowledge, the mortgaged property is not

subject to any mortgage or any lien whatsoever and is now in the
possession and full control of the above-named Mortgagor-Debtor;

4. That the Mortgagor-Debtor has failed to perform her obligation

under the aforementioned Real Estate Mortgage Contract and
Promissory Note;

5. That under the terms and conditions of the Real Estate Mortgage
Contract, the Mortgagee is entitled to foreclose extra-judicially the
mortgaged property, which is more particularly described as
follows:

TRANSFER CERTIFICATE OF TITLE – T-166216

“A parcel of land (lot 16, blk. 5 of the consolidation-subdivision

plan. Pcs-4-021063, being a portion of lots 6790, 6792, 6794, 6795,
6797, 9974 & 9975, Cad-168, Tanuan Cad. Lots 6793-A & 6793-B,
Psd-71221, lots 6798-A & 6798-B, Psd-041031-065509, lots 6799-A
& 6799-B, (LRC) 27609, L.R.C. Record No.), situated in the
Barangay Sulpok & Syplang, Tanuan City, Province of Batangas,
Island of Luzon. Bounded on the NW, along line 1-2 by lot 8, block
5; on the NE, along lines 2-11 by road 19; on the SW, along line 11-
1 by lot 15, block 5, all of the cibsivision plan. Beginning at point
marked “1” on plan being 8.79 deg. 44’E, 43.16 m. from BLLM 33,
Tanuan Cadastre.”

The Transfer Certificate of Title is attached hereto as annex “C”; and

 6. That by the terms and conditions of the Real Estate Mortgage
Contract herein-above referred to, the principal obligation of the
Mortgagor which has become overdue as of January 8, 2017 is in the
amount of Six Million Pesos (P6, 000, 000. 00), excluding penalties,
liquidated damages, past due interest, attorney’s fee representing
______% of the total obligation due, other charges and expenses of
foreclosure.

WHEREFORE, I respectfully request you to foreclose or take

possession of the property described in the afore-mentioned Real Estate
Mortgage and sell the same at Public Auction in accordance with
the provisions of Act 3135, as amended.

This 28th day of February, 2018 at _______________________,

Philippines.

ATTY. MARLO V. DESTURA, LL.M.

Counsel for the Petitioner-Mortgagee
109 Gil Fernando St., Sta. Elena, Marikina City
IBP No. 1047623; 01/31/18 Northern Samar
Roll of Attorney No. 42918, May 6, 1998
MCLE Compliance No. V-0004034; 10/07/2014
 VERIFICATION AND CERTIFICATION
AGAINST NON-FORUM SHOPPING

I, CHERYL LIM-CORDOVA, under oath, depose and state that:

1. I am the Mortgagee under the Deed of Real Estate Mortgage

executed on January 8, 2016, duly acknowledged before the notary public in
Makati City as shown by the Acknowledgement portion of the contract, and
such portion is hereto attached as Annex “A”.

2. I caused the above petition to be prepared and filed, and I have

read, and understood all the contents thereof;

3. All the allegations contained therein are true and correct to the
best of my own knowledge and authentic records;

4. I have not heretofore commenced any other action or proceeding

involving the same issue with the Supreme Court, the Court of Appeals or
different Divisions thereof, or any other court, tribunal or agency; and

5. And if I learn of such similar action(s) or proceeding(s), I hereby

undertake to promptly inform this court within five (5) days thereof.

IN WITNESS WHEREOF, I have hereunto set my hand this __ day of

February 2018 in _______________ City.

CHERYL LIM-CORDOVA
Affiant

SUBSCRIBED AND SWORN to before me this _____ day of February

2018 in ______________ City. Affiant showing to me her TIN No. 163-599-
264 issued in _________________________________.

Doc. No. _____;

Book No. _____;
Page No. _____;
Series of 2018