Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
BRANCH __
Santiago City

IN RE: PETITION FOR THE ISSUANCE OF

OWNER’S DUPLICATE COPY OF TCT NO.
(EP-30594) EPSC-3786 IN THE NAME OF
ROBERTO N. DE VERA RECORDED
IN THE REGISTRY OF DEEDS FOR
SANTIAGO CITY, ISABELA
x----------------------------------------------------x

ROBERTO N. DE VERA
Petitioner,
LRC. NO. 36-6___
-versus-

THE REGISTRY OF DEEDS FOR

SANTIAGO CITY, ISABELA
Respondent.
x-----------------------------------------------------x

FORMAL OFFER
OF DOCUMENTARY EXHIBITS
FOR THE PETITIONER

PETITIONER, through counsel, to the Honorable Court, hereby

formally offers the following documentary exhibits in addition to the
testimonial evidence already adduced in court, thus:

EXHIBIT “A” – Petition for the Issuance of Owner’s Duplicate

Copy of TCT No. (EP-30594) EPSC-3786;

EXHIBIT “A-1”- Signature of Petitioner, Roberto N. De Vera;

PURPOSE: To prove the fact of loss of the Owner’s Duplicate

Copy of TCT No. (EP-30594) EPSC-3786. It forms part of the direct
testimony of the Petitioner; part of the pre-trial and the record of the
case;

EXHIBIT “B” – Order issued by the Honorable Anastacio D.

Anghad dated September 06, 2019;
EXHIBIT “C” – Certificate of Posting issued at the Municipality
of San Isidro, Isabela;

EXHIBIT “D” – Certificate of Posting issued by the Register of

Deed of
Santiago City;

EXHIBIT “E” – Certificate of Posting issued by the Brgy.

Captain of Dona
Paulina, San Isidro, Isabela;

EXHIBIT “H” – Certificate of Posting at the Bulletin Board of

the Court;

COMMON PURPOSE: It forms part of the direct testimony of

the Petitioner; part of the pre-trial and record of the case. It is being
offered to prove that there was faithful compliance of the jurisdictional
requirement of posting of the Petition and its annexes in the
conspicuous places in the Municipal Hall of San Isidro, Isabela, in the
Office of the Registry of Deeds of Santiago City, in the Barangay Hall of
Brgy. Dona Paulina, San Isidro, Isabela and in the bulletin board of the
Regional Trial Court, Branch 36. It now forms part of the case;

EXHIBIT “F” – Affidavit of Loss dated September 18, 2018;

PURPOSE: It forms part of the direct testimony of the Petitioner;

part of the pre-trial and record of the case. To prove the fact of loss of
the Owner’s Duplicate Copy of TCT No. (EP-30594) EPSC-3786;

EXHIBIT “G” – Memorandum of Encumbrance;

PURPOSE: It is being offered to prove the fact of loss of the

Owner’s Duplicate Copy of TCT No. (EP-30594) EPSC-3786, to prove
that Petitioner caused its annotation at the dorsal portion of the
original copy of TCT No. (EP-30594) EPSC-3786 kept in the Registry of
Deeds for Santiago City; it forms part of the direct testimony of the
Petitioner; part of the pre-trial and record of the case.

EXHIBIT “I” – Electronic Machine Copy of TCT No. (EP-30594)

EPSC-3786 in the name of Roberto N. De Vera;

PURPOSE: It forms part of the direct testimony of the Petitioner;

part of the pre-trial and the record of the case. It proves that Roberto
N. De Vera is the registered owner of TCT No. (EP-30594) EPSC-3786
and the original copy of said title is intact, filed, registered and existing
in the Office of the Registry of Deeds for Santiago City, Isabela;

PRAYER
 WHEREFORE, it is so respectfully prayed of the Honorable Court
to admit the foregoing documentary exhibits and for the purpose for
which they are offered and to render judgment on the basis thereof.

Other reliefs just and equitable under the premises are likewise
prayed for.

Echague, Isabela for Santiago City, Isabela. February 21, 2020.

_________ LAW OFFICE

Counsel for the Petitioner
__________, __________,
Echague, Isabela

By:

ATTY. F________ M. G__________

Roll No. 71940
PTR No. 12381723/ 01- 08-20/ Echague,Isabela
IBP Receipt No. 043019/05-17-2018
MCLE Comp. No. V-0005915/10-01-2018
MCLE is valid until April 14, 2022
gm_james0031@yahoo.com / 0905-866-9095

The Branch Clerk of Court

Branch __, RTC
Santiago City

Please submit the foregoing Formal Offer of Documentary

Exhibits immediately upon receipt hereof for the favorable
consideration of the Honorable Court. Thank you.

F_____ M. G____________

Copy furnished (via registered mail):

REGISTRY OF DEEDS
FOR SANTIAGO CITY, ISABELA
Batal, Santiago City, Isabela

Explanation:
 Copy of the foregoing Formal Offer of Documentary Exhibits was
duly furnished the Office of the Registry Of Deeds for Santiago City,
Isabela in its given address via registered mail pursuant to Section 7 &
11, Rule 13 of the Rules of Court due to distance, time and expense to
effect personal service.

F_____ M. G____________