Republic of the Philippines

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 32
Agoo, La Union

IN RE: RE-ISSUANCE OF OWNER’S

DUPLICATE CERTIFICATE OF OCT. NO.
CLOA-8579 ISSUED IN THE NAME OF
ZOSIMO C. PULMANO, MARINA P. TISBE,
ANDREA P. ANDRADA, and MERCEDES
C. PULMANO IN LIEU OF THE ONE LOST

DEPARTMENT OF AGRARIAN REFORM

Represented by: CHRISTIANNE C. SUGUITAN
Provincial Agrarian Reform Program
Officer II of La Union
(RSRK Bldg., Purok 5, Biday, San Fernando
City, La Union)
Petitioner, ADMIN CASE NO. A-4035

-versus-

REGISTER OF DEEDS OF LA UNION,

(Sevilla Heights, Brgy. Sevilla, San Fernando
City, La Union)
Respondent.
x-------------------------------------------------------x

EX-PARTE MOTION FOR

VIDEOCONFERENCE HEARING
WITH MANIFESTATION AND
COMPLIANCE

Petitioner, Department of Agrarian Reform (DAR), represented by PARPO Christianne C.

Suguitan, through the undersigned counsel, most respectfully states:

1. During the last hearing on May 2, 2022, this Honorable Court ordered Petitioner to
present all the co-owners named in the lost title and suggested that witnesses maybe
presented via zoom specially if they are already senior citizens or physically
incapacitated;

2. It is likewise ordered that Petitioner should submit a Certification from the Register of
Deeds stating as to the number of Owner’s Duplicate Copy of OCT No. CLOA-8579
issued and that the original copy of said title is existing in its file;
 3. In compliance with the said Order, Petitioner able to confer with co-owner Sozimo
Pulmano who preferred to testify via zoom at his g-mail account
matt.pulmano@gmail.com;

4. With respect to the other co-owners, Petitioner learned that Mercedes Pulmano has
already died without issue as evidenced by her Certificate of Death (Annex “A”) while
Andrea Andrada is mentally ill who cannot talk with despite earnest efforts to do so by
the Petitioner;

5. Anent the required Certification, the Register of Deeds instead issued a Certified True
Copy of OCT No. CLOA-8579 (Annex “B”) to show that the original copy of the title is
on file with the said Office. The Register of Deeds likewise intimated that in the absence
of any inscription at the bottom of the title stating the number of copies of owner’s
duplicate copy issued, means that there was only one (1) copy of Owner’s Duplicate
Copy issued. However, a Certification to that effect may be issued through a court order.

PRAYER

WHEREFORE, premises considered, Petitioner DAR, represented by its duly representative,

PARPO Christianne C. Suguitan, through counsel most respectfully prays:

a.) That this Ex-Parte Motion for videoconference Hearing with Manifestation and
Compliance be taken due NOTICE and that witness Sozimo Pulmano be heard
through videoconferencing at his g-mail account;

b.) To receive and admit the Certified True Copy of OCT No. CLOA-8579 in lieu of the
required Certification to show that the original copy of OCT No. CLOA-8579 is in
the Register of Deeds’ existing file and that there is only one Owner’s Duplicate
Copy issued and consider it as a sufficient compliance to the said Order.

Other reliefs which are just and equitable are likewise prayed for.

City of San Fernando, for Agoo, La Union, May 24, 2022.

DEPARTMENT OF AGRARIAN REFORM

PROVINCE OF LA UNION
RSRK Building, Purok 5, Brgy. Biday
City of San Fernando, La Union

By

LOBAYTO P. LANG-AY
Attorney V
Roll No. 69055/05-02-17
PTR No. 1596809; 07-20-2020
 IBP Lifetime Membership No. 1068471
TIN No. 096-947-404
San Fernando City, La Union
Email address: langayloi@yahoo.com.ph
Cellular Phone No. 09436819825

NOTICE and COPY FURNISHED

The Register of Deeds

San Fernando City
La Union

The Branch Clerk of Court

Greetings:

As this matter can be acted upon ex-parte, please take notice that the foregoing Motion with
Manifestation and Compliance will be submitted for the consideration and resolution of the
Honorable Court immediately upon receipt hereof sans further oral argument.

LOBAYTO P. LANG-AY