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Petition Lost Title - Joaanne-Edited

This document is a petition filed with the Regional Trial Court requesting a new owner's copy of an original land title (OCT No. P-22390) be issued. It details that the petitioner's family has possessed the land title covering a property in Batac City, Ilocos Norte for generations since the original owner Adriana Bulong. However, the original title was damaged beyond recovery when the petitioner's home was flooded during Typhoon Ompong in 2018. The petition establishes the petitioner's legal right to the property and requests a new copy of the land title be issued.

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Mc Dalayap
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183 views6 pages

Petition Lost Title - Joaanne-Edited

This document is a petition filed with the Regional Trial Court requesting a new owner's copy of an original land title (OCT No. P-22390) be issued. It details that the petitioner's family has possessed the land title covering a property in Batac City, Ilocos Norte for generations since the original owner Adriana Bulong. However, the original title was damaged beyond recovery when the petitioner's home was flooded during Typhoon Ompong in 2018. The petition establishes the petitioner's legal right to the property and requests a new copy of the land title be issued.

Uploaded by

Mc Dalayap
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


First Judicial Region
Branch _____, City of Batac

In Re: PETITION FOR THE ISSUANCE


OF A NEW OWNER’S COPY OF
ORIGINAL CERTIFICATE OF TITLE
NO. P-22390 CAD Case No.
______________
JOANNE PARAOAN CORPUZ LRC Case No. _______
Petitioner, OCT No. P-22390
Lot No. 9459, Cad- 398
-versus- Batac Cadastre

THE REGISTER OF DEEDS


Represented by Atty. Kristelle
Quibuyen, in her capacity as OIC
Register of Deeds at Land Registration
Authority, Ilocos Norte, Batac City
Branch ,and ALL OTHER PERSONS
who have interest
x------------------------------x

PETITION
PETITIONER, through the undersigned counsel, unto this honorable
court most respectfully avers that:

1. Petitioner JOANNE PARAOAN CORPUZ, of legal age, married,


Filipino citizen and a resident of Brgy. 16 Quiling Norte, Batac City,
Ilocos Norte, Philippines where he may be served with lawful
processes and other notices of this Honorable Court;

2. Respondent is impleaded in her capacity as OIC Register of Deeds of


City of Batac, 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
Batac City;

3. ADRIANA BULONG is the owner of a parcel of land covered by


Original Certificate of Title No. P-22390 more particularly described
as follows:

“A parcel of land designated as Lot No. 9459 CAD-398


located at Brgy 16 Quiling Norte, Batac City, Ilocos Norte.
1
Bounded on the SW., along line 1-2 by Lot 9457, CAD-398;
on the NW., along lines 2-3 by lot 9456, Cad-398; on the NE.,
along lines 3-4 by lot 9462, Cad-398; and on SE., along line
4-5 by lot 9460, Cad-398; and along line 5-1 by lot 9458,
Cad-398, containing an area of FOUR THOUSAND ONE
HUNDRED AND SEVENTY FOUR (4,174) SQUARE
METERS”

(The electronic copy of the OCT No. P-22390 is hereby


attached and marked as ANNEX “A” and made an integral
part of this petition.)

4. That on April 15, 1912 ADRIANA BULONG married one


ROPERTO PARAOAN

(Copy of the Marriage Certificate of ADRIANA BULONG and


ROPERTO PARAOAN is hereby attached and marked as
ANNEX “B”, and made an integral part of this petition)

5. That after their marriage ADRIANA BULONG also used ADRIANA


BULONG PARAOAN as her name in her other transactions;

6. That on September 25, 1980 ADRIANA BULONG died;

(Copy of the Certificate of Death of ADRIANA BULONG


(ADREANA B. PARAOAN) is hereby attached and marked as
ANNEX “C”, and made an integral part of this petition)

7. That the name of ADRIANA BULONG/ADRIANA B. PARAOAN


on her Certificate of Death was misspelled to ADREANA B.
PARAOAN;

(Copy of an AFFIDAVIT OF TWO DISINTERESTED PERSON


to prove that ADRIANA BULONG and ADREANA B.
PARAOAN is one and the same person is hereby attached and
marked as ANNEX “D”, and made an integral part of this
petition)

8. That prior to the death of the late ADRIANA BULONG, she entrusted
the possession of OCT P-22390 to her daughter TEREZA PARAOAN
CORPUZ;

(Copy of the AFFIDAVIT OF TWO DISINTERESTED


PERSON to prove that TEREZA PARAOAN CORPUZ is a
daughter of ADRIANA BULONG, in lieu of the NEGATIVE
CERTIFICATION issued by the PHILIPPINE STATISTICS
AUTHORITY and CITY of BATAC, is hereby attached and

2
marked as ANNEX “E”, ANNEX “E-1”, and “E-2”
respectively and made an integral part of this petition)

9. That after some time TEREZA PARAOAN CORPUZ, passed


possession of the OCT P-22390 to the Petitioner because he is her
child and housemate;

(Copy of the birth certificate of one JOANNE PARAOAN


CORPUZ, to prove that he is a son of TEREZA PARAOAN
CORPUZ, is hereby attached and marked as ANNEX “F” and
made an integral part of this petition)

10. That on May 24, 2017, TEREZA PARAOAN CORPUZ died;

(Copy of the Certificate of Death of TEREZA PARAOAN


CORPUZ, is hereby attached and marked as ANNEX “G” and
made an integral part of this petition)

11. That Petitioner is one of the Heirs of ADRIANA BULONG;

(Copy of the FAMILY TREE subscribed and sworn by the Heirs


of ADRIANA BULONG is hereto attached and marked as
ANNEX “H” and made an integral part of this petition)

12. That the possession of the OCT P-22390 in the hands TEREZA
PARAOAN CORPUZ and later on to the Petitioner is known to all
the heirs of ADRIANA BULONG;

13. That two of the heirs of ADRIANA BULONG namely SABAS A.


PARAOAN and CRISPINA P. LACAMBRA executed a judicial
affidavit testifying to the fact that Petitioner is in possession of the
OCT P-22390;

(Copy of JUDICIAL AFFIDAVITS executed by SABAS A.


PARAOAN and CRISPINA P. LACAMBRA are hereto attached
and marked as ANNEX “I” and ANNEX “J” respectively, and
made an integral part of this petition)

14.That the OCT P-22390 was kept by the petitioner in a long brown
envelope in his old cabinet “lakasa” inside his room on the
groundfloor of their house, including other equally important
documents;

15.That on September 2018 the country was devastated by the Typhoon


Ompong, the northern part of the country was highly damaged
because of the fierce wind and heavy rain of the said typhoon;

3
16.That when Typhoon Ompong land fall in Northern Luzon, Petitioner’s
house was damaged and was flooded due to heavy rain;

17.That after Typhoon Ompong left the Philippines, Petitioner started to


fix and repair the damage it caused in their house, it was when he
learned that all the documents placed in his old cabinet “lakasa”
inside his room on the groundfloor of their house were completely
soaked with flood water;

18.Petitioner tried to save the said title but the damaged caused by the
flood was beyond recovery;

19.That by reason thereof, Petitioner executed Affidavit of Loss which


was duly notarized by the ATTY. ERNIELINEO B. LABRADOR,
dated March 7, 2020 with Doc. No. 419, Page No.97, and Book
No.XXXVII, Series of 2020;

(Copy of the Affidavit of Loss relating to the OCT No. P-22390


is attached and marked as ANNEX “K” and made an integral
part of this petition.)

20.That after which, the Affidavit of Loss was registered with the
Register of Deeds at Batac City and thereafter annotated in the
Original Certificate of Title as Entry No. 2020000298 dated March 9,
2020;

(Copy of the Entry in the Memorandum of Encumbrances of


OCT No. P-22390 is attached and marked as ANNEX “A-5”
and made an integral part of this petition)

21.That the Original Certificate of Title No. OCT No. P-22390 has no
existing encumbrances and / or lien nor were they confiscated, seized
or levied upon by virtue of any lawful order;

(Copy of the Memorandum of Incumbrances of OCT No. P-


22390 is attached and marked as ANNEX “A-3”and “A-4”
and made an integral part of this petition)

22.That a SPECIAL POWER OF ATTORNEY (SPA) was executed


by the Heirs of ADRIANA BULONG authorizing JOANNE
PARAOAN CORPUZ to file and sign this petition in their behalf;

(Copy of the Special Power of Attorney is attached and marked


as ANNEX “L” and made an integral part of this petition)

PRAYER

4
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 copy of the OCT No. P-22390 as null and
void and that a New Owner’s Copy of be issued in lieu thereof.

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

_________________ at Paoay, Ilocos Norte.

LABRADOR DAGDAGAN MARCOS LAW OFFICES


Counsel for the Petitioner
Barangay # 9 San Pedro, Paoay, Ilocos Norte

By:

ERNIELINEO B. LABRADOR
Brgy # 9 San Pedro, Paoay, Ilocos Norte
Roll of Attoney No. 64408/TIN 160-162-172
Admitted to the Bar on April 28, 2015
IBP OR No. 0990687 (Lifetime)/ 3.14.16 Laoag City/Ilocos Norte
PTR No. 2268363/01.19.20/ Laoag City/Ilocos Norte
eblabrador1973@yahoo.com.ph
MCLE Compliance No. VI-0005295

VERIFICATION/CERTIFICATION

KNOW ALL MEN BY THESE PRESENTS:

I, JOANNE PARAOAN CORPUZ, of legal age, married, Filipino


citizen and a resident of Brgy. 16 Quiling Norte, Batac City, Ilocos Norte,
Philippines, after having been duly sworn to in accordance with law, hereby
voluntarily depose and state:

1. That I am the petitioner in the above-captioned case;

2. That I have caused the preparation of the foregoing petition;

3. That I have read the said petition and that all the allegations therein
are true and correct to the best my personal knowledge and/ or
based on authentic records;

4. That I attest to the truthfulness of the foregoing facts,

5. That I further declare that;

5
a. I have not commenced any other action or proceeding
involving the same issues or of the same nature raised in this
Petition before the Supreme Court, the Court of Appeals, or any
other tribunal or agency and to the best of my knowledge, no
such action or proceeding is pending in the Supreme Court, the
Court of Appeals, or any other tribunal or agency;

b. If there is such other pending action or proceeding a complete


statement of the present status thereof;

c. If I should thereafter learn that a similar action or proceeding


has been filed or is pending before the Supreme Court, the
Court of Appeals, or any other tribunal or agency, I undertake
to inform this Honorable Court within five (5) days from such
knowledge.

IN TRUTH WHEREOF, I have hereunto set our hands this


_______________ at Paoay, Ilocos Norte, Philippines.

JOANNE PARAOAN CORPUZ


Affiant

SUBSCRIBED AND SWORN to before me this


_________________________ at ________________ Philippines. Affiant
exhibited to me ________________.

Doc. No. :________ ATTY. ERNIELINEO B. LABRADOR


Page No. :________ NOTARY PUBLIC
Book No. :________ UNTIL DECEMBER 31, 2020
Series : of 2020 PTR No. 2268363/01.19.20/P.T.O. I.N.
IBP No. 0990686 (LIFETIME)/03.14.16/L.C., I.N.
ROLL No. 64408/TIN 100-162-172
MCLE Compliance No. VI-0005925
Brgy 9 San Pedro, Paoay, IlocosNorte

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