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Republic of the Philippines


REGIONAL TRIAL COURT
7th Judicial Region
Branch 76
City of Naga, Cebu

IN RE: PETITION FOR THE ISSUANCE


OF OWNER’S DUPLICATE OF ORIGINAL
CERTIFICATE OF TITLE NO. OP-58002
IN LIEU OF THE ONE THAT WAS LOST.

PILAR LLANTO SANCHEZ


Petitioner,

-versus- LAND REGISTRATION CASE NO. _______

REGISTER OF DEEDS OF
CEBU PROVINCE
Respondent.
x----------------------------------------------x
PETITION

COMES NOW, the Petitioner through undersigned counsel and unto this
Honorable Court, most respectfully states:

1) That Petitioner, PILAR LLANTO SANCHEZ, is a Filipino, of legal age,


WIDOW, and a resident of East Poblacion, City of Naga, Cebu. She can be
served with order and other processes of this court relative to her petition at her
address and at the office of the undersigned counsel;

2) That Petitioner owns a parcel of land known as Lot No. 53 Cad. 747-D,
situated in East Poblacion, City of Naga, Cebu, covered then by OCT No. OP-
58002 with an area of 274 square meters;

3) That the owner’s copy or duplicate of Original Certificate of Title No.


OP-58002 covering Lot No. 53 Cad 747-D was in petitioner’s possession after
she was issued and awarded with a Homestead Patent under her name on the
subject lot. A machine copy of the said Original Certificate of Title No. OP-
58002 is hereby attached as Annex “A”;

3) That petitioner safe keep the said Original Certificate of Title No. OP-
58002 inside her cabinet for so many years but she got surprised when it was
inadvertently lost in her possession when it can never be retrieved nor found in
her cabinet; .

4) That despite, diligent efforts exerted to search for the said owner’s
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copy or duplicate of Original Certificate of Title No. OP-58002, petitioner


can no longer found the same such now that she believed that it is now lost
beyond recovery;

5) That Petitioner executed an Affidavit of Loss to the said ORIGINAL


CERTIFICATE OF TITLE NO. OP-58002 and cause the same to be
filed and be annotated in the Register of Deeds of Cebu Province. A copy
of the said Affidavit of Loss is hereby attached as Annex “B”;

6) That the said Affidavit of Loss was received by the Register of Deeds of
Cebu Province for it to be annotated in the original copy of the Original
Certificate of Title No. OP-58002. The stamp received by the Register of
Deeds of Cebu Province on the Affidavit of Loss is hereby attached as
Annex “C”;

7) That said owner’s duplicate has never been pledged or otherwise


delivered to any person or private entity to guarantee any obligation for
any other purposes;

PRAY E R

WHEREFORE, the petitioner respectfully prays this Honorable Court to


declare null and void the owner’s duplicate of Original Certificate of Title
No. OP-58002 which has been lost, and to order and direct the Register of
Deeds of Cebu Province, after payment of the fees prescribed by law, to issue in
lieu thereof of a new owner’s duplicate of ORIGINAL CERTIFICATE OF
TITLE NO. OP-58002 which shall in all respects be entitled to like faith and
credit as the original duplicate, in accordance with Section 109 of Act 496
otherwise known as Land Registration Law, as amended by Presidential Decree
No. 1529.

Other reliefs are likewise prayed for as may be warranted.

Cebu City, Philippines, July 15, 2019.

DAVIDE & SUSUSCO LAW OFFICE


COUNSEL FOR THE PETITIONER
Central Poblacion, City of Naga, Cebu
Beside UCPB
Tel. No. (032) 4899616
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ATTY. GIOVANNI D. SUSUSCO


IBP NO. AR55344831/12/13/2018/ 0Cebu City
PTR No. 3297652/ 01-03-2019/ Talisay City
Roll of Attorneys No. 53097
Admitted to the Bar on April 26, 2007
MCLE COMPLIANCE NO. V-0008256