Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch _____, Laoag City

In Re: PETITION FOR THE RE-

ISSUANCE OF A SECOND
OWNER’S DUPLICATE COPY
OF TRANSFER OF CERTIFICATE
OF TITLE

EDWARD T. VALDEZ CAD Case No.

Petitioner, LRC Record No.
Lot No. _____
-versus- TCT No T-_____
Laoag Cadastre
THE REGISTER OF DEEDS,
Represented by ATTY AUGUSTUS
LUCAS, in his capacity as Register of
Deeds of Laoag City
Respondent,
x--------------------------------------------------------------------------x

PETITION

PETITIONER, through the undersigned counsel, unto this

honorable court most respectfully avers that:

1. Petitioner is of legal age, single, Filipino citizen and a resident

of Brgy 54. Camangaan, Laoag City, where she may be served
with lawful processes and other notices of this Honorable Court;

2. Respondent is impleaded in his capacity as Register of Deeds

of Laoag City, who is the custodian and person accountable to
all certificate of title of lots issued in Ilocos Norte, and in all the
registration of all legal documents affecting the title and
ownership of real properties. He may be served with summons
and other legal processes of this Honorable Court at Office of
the Registry of Deeds Laoag City;

3. Petitioner is the sole owner of the following parcel of land

designated as:

a. Lot No. 29851 of the Cadastral Survey of Laoag situated

in Barrio Vira City of Laoag currently known as Brgy. 54-A
 Lagui-Sai, Laoag City, Ilocos Norte containing an area of
867 square meters (agricultural) covered under TCT No.
T-33457 with Tax Declaration No. 17-0052-01463 and
Property Identification No. 101-02-0052-35-008. The
electronic copy of the Certificate of Title and the Tax
Declaration are hereto attached and marked as Annexes
“A” and “B” respectively;

4. That the Petitioner was the one who personally kept the
Transfer of Certificate of Title Nos. T-33457;

5. That Petitioner placed the same Certificate of Title in a brown

folder contained in a plastic envelope and kept it in one of her
cabinet at his residence at Brgy 54, Camangaan, Laoag City;

6. That on 2017, when Petitioner looked for the said Transfer

Certificate of Title, he discovered that the plastic envelope
containing the said Transfer Certificate of Title could no longer
be found;

7. That petitioner searched thoroughly the sad cabinet as well as

the other cabinets in their home hoping that it was just
misplaced but the same could not be found and that he asked
all her family members, relatives and co-owners if they
borrowed it from him, but to his dismay, the same was not even
in their possession;

8. That despite diligent and serious efforts on the part of the

Petitioner in the search of said Transfer of Certificate of Title,
he could no longer locate it, creating a conclusion in his mind
that the Transfer Certificate of Title was lost and beyond
recovery;

9. That by reason thereof, he executed an Affidavit of Loss which

was duly notarized by the undersigned counsel, dated
___________ with Doc. No. ____, Page No. __, and Book No.
____, Series of ______ attached and marked and made an
integral part hereof as Annex “__”.

10. That after which, the document was registered and

thereafter annotated in the Certificate of Title TCT No. T-_____
as Entry Nos. 2018000150 dated February 7, 2018 which is
attached and marked hereof as Annex “__”;

11. That the Transfer of Certificate of Title Nos. ______ and

have no existing encumbrances and / or lien nor were they
confiscated, seized or levied upon by virtue of any lawful order
 as evidenced by the earlier submitted and marked as electronic
copy of the annotated Certificates of Title, Annex| “__”;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed

unto this Honorable Court that after due notice and hearing, a
judgment be rendered declaring the owner’s duplicate copy of the
Transfer of Certificate of Title Nos. T-_____ as null and void and that
a second owner’s duplicate copy to be issued in lieu thereof.

Other just and equitable relief and remedies are likewise prayed
for.

February 9, 2018 at Paoay, Ilocos Norte.

ATTY. JOHN NICO R. LUCERO

Counsel for the Petitioner
PTR NO. 9663965/1-5-18/PTO I NORTE
IBP NO. 0990686 (LIFETIME)/3-14-16
ROLL NO. 64408/TIN 160-162-172
BRGY 13 NAGILIAN
LAOAG CITY, ILOCOS NORTE, PHILIPPINES
MCLE Compliance No. VI-0005295