Republic of the Philippines

REGIONAL TRIAL COURT OF PALAWAN

AND PUERTO PRINCESA CITY
Fourth Judicial Region
Branch ___
Puerto Princesa City

IN RE: PETITION FOR ISSUANCE

NEW OWNER’S DUPLICATE
COPY OF TRANSFER
CERTIFICATE OF TITLE NO.
19796 IN LIEU OF LOST
ONE

CERELINA C. LAGAN, LAND CASE NO. ____

Petitioner,
For: Issuance of
- versus - Owner’s Duplicate
Copy of Transfer
THE REGISTER OF DEEDS Certificate of Title
FOR THE CITY OF PUERTO
PRINCESA
Respondent.
x----------------------------------------------x

PETITION

COMES NOW the Petitioner through the undersigned

counsel most respectfully states that:

1. That Petitioner is of legal age, married, Filipino and a resident

of Brgy. San Jose, Puerto Princesa City;

2. That Petitioner may be served with pleadings, notices, orders

and other court processes through the undersigned counsel;

3. That Petitioner is the true and absolute owner of that certain

parcel of land situated in the Barrio of Tiniguiban, City of
Puerto Princesa, containing an area of FOUR THOUSAND
EIGHT HUNDRED SEVENTY SEVEN (4877 SQ.M.) more or
less, embraced and covered by Transfer Certificate of Title
No. 19796 issued under the name of herein Petitioner by the
Registry of Deeds for the City of Puerto Princesa; copy of TCT
No. 169807 is hereto attached as Annex “A”;
4. That pursuant to existing laws, herein Petitioner was issued
with the Original Owner’s Duplicate Copy of TCT No. 19796;

5. That Petitioner diligently kept the Original Owner’s Duplicate

Copy of TCT No. 19796 at the cabinet of her house and
sometime in 2005, she discovered while cleaning the house
that Original Owner’s Duplicate Copy of TCT No. 19796 was
missing and could no longer be found;

6. That despite his diligent efforts to locate the land title, she
could no longer find it. This fact had been reported to the
Registry for the City of Puerto Princesa through a request for
annotation of the Affidavit of Loss by the Petitioner; copy of
the Affidavit of Loss is hereto attached as ANNEX “B” the
said annotation is sub-annexed as ANNEX “A-1”;

7. That the said parcel of land was declared in the name of the
Petitioner for taxation purposes under Tax Declaration No.
026-20787; copy of the Tax Declaration is hereto attached
as ANNEX “C”;

8. That the corresponding real property taxes had also been

paid by the Petitioner; copy of the Tax Clearance is hereto
attached as ANNEX “D”;

9. That being the registered owner of the property above-

mentioned, Petitioner had all the while been in the peaceful
possession, ownership and dominion thereof, adverse to any
other person and had declared it for purposes of taxation in
her name and had faithfully paid the taxes due thereon;

10. That the owner’s duplicate copy of TCT No. 19796 was not
seized to satisfy for any debt or obligation nor was it taken
for any tax delinquency;

11. That pursuant to the provisions of Presidential Decree No.

1529 otherwise known as the Property Registration Decree,
herein Petitioner is endowed with sufficient legal interest and
personality to petition for re-issuance of the lost owner’s
duplicate copy of TCT No. 19796.

PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed of this Honorable Court, that after due notice and
hearing, an Order be issued directing the Register of Deeds for
the City of Puerto Princesa to issue, in lieu of the lost one, a new
owner’s duplicate copy of TCT No. 19796 in the name of the
herein Petitioner.
Other reliefs and remedies are likewise prayed for.
Respectfully submitted.
Puerto Princesa City, Palawan, this May 21, 2019

ATTY. ARIEL A. ABIS

Counsel for the Petitioner
Attorney’s Roll No. 67114
PTR No. 11297224; 01-28-19/Palawan
IBP No. 075843; 03 – 07 – 19/Palawan
MCLE No. VI – 0021606
Compliance Date: March 28, 2019
Valid Until: April 14, 2022
c/o Provincial Legal Office, Room 3C, 3rd Floor
Capitol Main Bldg., Rizal Ave. cor Fernandez St.
Puerto Princesa City, 5300

VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines )

Puerto Princesa City ) S. S.

I, Cerelina C. Lagan, of legal age, married, Filipino and a

resident of Brgy. San Jose, Puerto Princesa City, Palawan, on oath,
depose and state:

1. That I am the Petitioner in the above-entitled case;

2. That I caused the preparation of the above-captioned
Petition;
3. That I have read and fully understood the averments
contained therein and the same are true and correct to the
best of my personal knowledge and authentic documents;
4. That I further certify that I have not commenced any other
actions or proceedings involving the same issue in the
Supreme Court, the Court of Appeals, or any tribunals or
agencies and that if there is any of such action or proceeding
filed or pending I undertake to report the fact within five (5)
days thereafter to the court or agency wherein the original
 pleading and sworn certification contemplated herein have
been filed.

In witness hereof, I affixed my signature this ___ day of ____

2019 at Puerto Princesa City.

CERELINA C. LAGAN
Affiant

SUBSCRIBED AND SWORN TO before me this ____ day of _____

2019 at Puerto Princesa City, Palawan, affiant having exhibited to
me her _______________ issued by ______________.

Doc. No.______; Notary Public

Page No. _____;
Book No._____;
Series of 2019.