Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
BRANCH 13
BAGUIO CITY

KEVIN MCCALLISTERS, LAND REGISTRATION

CASE NO. N(LRC)-01-22
PETITIONER,

-versus- FOR: PETITION FOR THE

REGISTRATION OF
UNREGISTERED
LAND LOCATED
AT BAKAKENG
BAGUIO CITY

REGISTER OF DEEDS OF BAGUIO CITY

RESPONDENT

x---------------------------------------x

PETITION

COMES NOW, Plaintiff through the undersigned counsel,

unto this Honorable Court, most respectfully aver, THAT:

1. Plaintiff, of legal age, Filipino, single and a resident of #47 B Sto.

Rosario Campo Sioco, Baguio City, has the capacity to sue and be
sued and may be served with notices and other court processes
 through the undersigned counsel Attorney Catherine O’hara.
2. Respondent is the Register of Deeds of Baguio City which has a
official address at City Hall Compound, Baguio City, where it may
be served with summons, notices and other court processes;
3. Petitioner is applying for the registration of the unregistered land
located at Phase 2 Eaglecrest Villa Bakakeng Baguio City (subject
lot);

“A PARCEL OF LAND (Lot 123, Cad. 111, Bakakeng Cadastre

(AP-01-002345) situated in the Phase 2 Eaglecrest Villa Bakakeng.
Bounded on the S., along lines 1-2, by Lot 1230; on the W., along
lines 1-2-3-4 by Lot 1232; on the N., along lines 5-6 by Lot 1230;
and on the E., along line S 3-4-5 by Lot 1228, all of the Cad. 123
Bakakeng Cadastre.
x x x
Containing an area of FIFTY THOUSAND (50,000) square
meters more or less."

4. Petitioner has been occupying the subject lot for twelve (12) years
starting from June 20, 2010 up to present;
5. Petitioner-Applicant and his predecessors-in-interest has been on
open, peaceful, continuous, uninterrupted possession in the
concept of an owner of the above-described property since time
immemorial.

PRAYER

WHEREFORE, it is respectfully prayed that the Register of Deeds of

Baguio City issue an original certificate of title of the lot located at Phase 2
Eaglecrest Villa Bakakeng Baguio City registered in the name of the
petitioner.
Other just and equitable reliefs are likewise prayed for

November 15, 2022, at Baguio City, Philippines

Atty. Catherine O’hara

Counsel for the Petitioner
Republic of the Philippines)
City of Baguio )s.s.
x-----------------------------------------x

V E R I F I C A T I O N/ C E R T I F I C A T I O N

I, KEVIN MACCALLISTERS, of legal age, after having been duly

sworn to in accordance with law, hereby depose and say:

That I am the Plaintiff in the above-entitled case;

That I have caused the preparation and filing of the same;

That all the facts alleged therein are true and correct on my own
knowledge and belief and authentic records;

That I have not heretofore commenced any other action or

proceeding including the same issues in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;

That no such action or proceeding is pending in the Supreme

Court, the Court of Appeals, or different Division thereof, or any other
tribunal or agency;

That if there is such action or proceeding, we shall state the status

thereof;

That should I thereafter learn that a similar action or proceeding

has been filed or is pending before the Supreme Court, the Court of
Appeals, or different Division thereof, or any tribunal or agency, we will
undertake to promptly inform the aforesaid courts and such other
tribunal or agency of that fact within five (5) days therefrom.
 IN WITNESS WHEREOF, I have hereunto affixed my signature
this 15th day of November, 2022 at Baguio City, Philippines.

KEVIN MACCALLISTERS
Affiant

SUBSRIBED AND SWORN to before me this 15th day of

November 2022, affiant exhibiting to me his PRC ID No. 12345678 issued
on June 20, 2012, in Baguio City, Philippines.

ATTY. PATRICK JOHNSON

Notary Public
Rm. 123 Insular Life Building, Baguio
City
Roll of Attorney No. 24568
IBP No. 12344, August 5, 2011/Baguio
PTR No. 235462S, June 2, 2019/Baguio
MCLE COC No. 0030312; 05.10.2019

Doc. No.3;
Page No.4;
Book No. II;
Series of 2022.