Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
Branch _____
City of Ilagan

RE: ISSUANCE OF OWNER’S COPY

OF TRANSFER CERTIFICATE OF
TITLE WITH TAX DECLARATION
NO. 99-20-007-0477, IN LIEU OF
THE LOST ONE.

L.R.C. ADM Case No. _________

GERSHONJONE & SHERWIN

ARIEL BARBERO,
Petitioners,
x------------------------------------------x

PETITION

PETITIONERS, by counsel, to this Honorable Court, most respectfully

states that:

1. We are of legal age, Filipinos, and residents of Block 66 Lot 1 Fiesta

Communities Barangay, Sabanilla, Mexico, Pampanga where we may be
served with summons and other court processes;

2. We are the registered owners of a parcel of land situated in Burgos,

Municipality of Naguilian, Province of Isabela, covered and embraced in
Tax Declaration No. 99-20-007-0477 hereto attached as Annex “A”;

3. We have kept the Owner’s Copy of the certificate of title in a secure place
in our residence at #483 Pinmaludpod Urdaneta City, Pangasinan with
other important documents and valuables;

4. In the year 2009, there was a strong typhoon in the Luzon area with the
typhoon name ‘Ondoy/Peping’ where rains and floods occurred in our
area. This led to our home being flooded and our belongings drenched;

5. We had evacuated the area to ensure our safety and did not secure any
papers or documents with us during our evacuation;

6. Returning to our home, we can no longer locate said Owner’s Copy of the
title being that everything was drenched and unrecognizable;
 7. We could only conclude that said Owner’s Copy was lost during the
course of the typhoon in our area;

8. Given Petitioner’s and their family’s extremely diligent and ultimately

futile efforts to locate the said Owner’s Copy, we are left with no other
choice but to consider the same as lost and beyond recovery;

9. The Owner’s duplicate copy of said title has never been delivered to any
person or entity to secure the payment of any obligation, nor has it been
the subject or any transaction.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable Court

that, after due notice and hearing, an Order be issued directing Respondent
Register of Deeds of Ilagan to issue a new duplicate Owner’s Copy to Transfer
Certificate of Title with Tax Declaration No. 99-20-007-0477, to be regarded as
the Original Certificate of Title for all legal intents and purposes, pursuant to
law.

Other reliefs just and equitable are likewise prayed for.

City of Ilagan, Isabela, Philippines, ____________________, 2018.

Republic of the Philippines }

Done in the City of Ilagan }SS

VERIFICATION and CERTIFICATION

We, GERSHONJONE & SHERWIN ARIEL BARBERO, Filipino citizens,

and with residence and postal address at Block 66 Lot 1 Fiesta Communities
Barangay, Sabanilla, Mexico, Pampanga, on oath, do hereby depose and state
that;

We are the Petitioners in the foregoing petition;

We have caused the preparation of this pleading. We have read and

understood the same, and the contents thereof are true and correct of our own
personal knowledge or based on authentic documents.

We further certify that we have not commenced any other action or

proceeding involving the same issues in the Supreme Court, Court of Appeals,
or any other court, tribunal, agency; and that to the best of our knowledge, no
such action or proceeding is pending therein; and should we learn of the fling
or pendency of such action or proceeding, we hereby undertake to notify this
Honorable Court within five (5) days from knowledge.
 IN WITNESS WHEREOF, we have hereunto set out hand this ______ day
of ___________________, 2018 at the City of Ilagan, Isabela, Philippines.

GERSHONJONE BARBERO SHERWIN ARIEL BARBERO

Petitioner Petitioner

SUBSCRIBED AND SWORN to before me in the City of Ilagan this _______

day of _________________, 2018. Affiants exhibiting to me their government
issued IDs ______________________________________ and
_______________________________ respectively, that they are the same person
who personally signed the foregoing affidavit before me and acknowledged that
they executed the same.

Doc No. _______

Page No. ______
Book No. ______
Series of 2018