REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
BRANCH __
BINANGONAN, RIZAL

IN RE: PETITION FOR ISSUANCE OF

NEW OWNER’S DUPLICATE COPY
OF ORIGINAL CERTIFICATE OF TITLE
NO. BP-580 IN LIEU OF THE LOST ONE

LRC RECORD NO. _______

ARIEL M. GOTO
AS REPRESENTED BY FLERIDA GOTO PATAG
Petitioner.
X--------------------------------------------------X

PETITION

COMES NOW, the above-named petitioner, thru and by its undersigned

counsel, and to this Honorable Court, respectfully states :

1. That the Petitioner is a of legal age, Filipino citizen, and resident of P.

Burgos St., Brgy. Lunsad, Binangonan, Rizal, represented by Flerida

Goto Patag , likewise of legal age, Filipino citizen and resident of. P.

Burgos St., Brgy. Lunsad, Binangonan, Rizal,Attached is the Special

Power of Attorney marked as “Annex A” and made an integral part

hereof;

The Registry of Deeds of Binangonan, Rizal maybe served with

summons and other court processes at the Office of Register of

Deeds,Binangonan,Rizal;

2. That Petitioner is the registered owner of a parcel of land embraced in

and covered by OCT BP-580 issued by the Register of Deeds of

Province of Rizal. A copy of the certified true copy of the said Original

Certificate of Title is hereto attached and marked as “Annex B”;

3. That the owner’s duplicate of said certificate of title was lost in his

possession and all efforts exerted to recover the same since then have

been vain. A copy of the duly executed Affidavit of Loss of the Petitioner

is attached and marked as Annex “C” and made an integral part

hereof;

4. That said certificate of title has never been pledged or otherwise

delivered to any person or entity to guarantee to any obligation or for

any other purpose ;

WHEREFORE, the petitioner respectfully prayed of this Honorable

Court that after due notice and hearing, issue an order directing the

Register of Deeds of Binangonan, Rizal after payments required by law to

issue a new owner’s copy of Original Certifictate of Title No. BP 580 in the

name of the herein Petitioner with the same validity as old ones and

declaring the owner’s duplicates which were missing to be null and void

and of no force and effect.

2 March 2020, Cainta, Rizal for Binangonan,Rizal.

ATTY.MARIA SALVE C. RUBAYA-ADAMOS

Counsel for the Petitioner
Unit 311 Bldg 2 East Summit Residences,
Ortigas Ave. Ext., Brgy. San juan,Cainta, Rizal
PTR No.13760073A / Jan. 3, 2020/Rizal
IBP Lifetime Roll No. 09047
MCLE Compliance No.VI-0004663/
December 5, 2017, Pasig City
Roll No. 55320
Email address: atty.salve@yahoo.com
 VERIFICATION AND CERTIFICATION
ON NON-FORUM SHOPPING

I , FLERIDA G. PATAG subscribing under oath, depose and state that:

1. I am the representative of the above named petitioner ;

2. I caused the preparation of the above petition; I have read the contents
thereof and all the allegations therein contained are true and correct of
our own personal knowledge and based on authentic records.
3. I have not commenced any action or proceeding involving the same
parties and issues before the Supreme Court or any other court or
government agency or tribunal. Should I learn that there is another
action pending with the Supreme Court or any court or other
government agency or tribunal, I undertake to report the same to the
Honorable Court within five (5) days from knowledge thereof.

FLREIDA G. PATAG
Affiant
ID NO._________

SUBSCRIBED AND SWORN to before me this _____________2020 at

____________________, Philippines. Affiant exhibited to me her Competent
Evidecne of Identity abovedescribed.

NOTARY PUBLIC
Doc. No. ____;
Page No.____;
Book No.____;
Series of 2020..