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Republic of the Philippines

REGIONAL TRIAL COURT OF ZAMBOANGA DEL NORTE


Ninth Judicial Region
Branch 28
Liloy, Zamboanga del Norte

MYRNA BARBASO GIPULAN, MISC. SP. PROC. NO.________


duly represented by EVAMIE
B. MORENO,
Petitioner, -for-

- versus - “PETITION FOR ISSUANCE


OF NEW OWNER’S
THE LOCAL REGISTER OF DUPLICATE COPY OF
DEEDS FOR PROVINCE OF TRANSFER CERTIFICATE OF
ZAMBOANGA DEL NORTE, TITLE T-16604 IN LIEU OF
Respondent. THE LOST ONE”
X---------------------------------/

PETITION

PETITIONER, through the undersigned counsel, and unto


this Honorable Court, for a valid and meritorious cause of
action, most respectfully allege:

1. That petitioner MYRNA BARBASO GIPULAN, is duly


represented to file this petition by EVAMIE B. MORENO, of
legal age, Filipino, single, with office address at RG Builders,
Talinga, Leon B. Postigo, Zamboanga del Norte, the place
where she may be served with summons and other notices of
this Honorable Court. A copy of a Special Power of Attorney
dated July 14, 2021 is attached as Annex “A”;

2. That respondent is herein impleaded as the head of


office of the Local Registry of Deeds for the Province of
Zamboanga del Norte, with office address at Back Capitol Site,
Estaka, Dipolog City, the address where he may be served with
summons and other notices of this Honorable Court;

3. That the parcel of land subject of this petition is


registered under the name of Gila S. Barbaso, Filipino, of legal
age, married to Bernardino E. Barbaso and a resident of Liloy,
Province of Zamboanga del Norte, which parcel of land is more
particularly described as follows:

“A parcel of land Lot No. 395, Pls-65 (Philcusa-Foa),


situated in the Barrio of Kayok, Municipality of Liloy, Province of

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Zamboanga del Norte, Island of Mindanao. Xxx containing an
area of Two Hundred Sixteen Thousand Eight Hundred Seventy
Three (216,873) square meters covered under Transfer
Certificate of Title No. T-16604.”

4. That the certified true copy of the Transfer Certificate


of Title No. T-16604 is hereto attached as Annex “B”;

5. That Petitioner is one of the co-owners and lawful co-


possessors of the subject property described above being one
of the surviving heirs of Spouses Bernardino Barbaso and Gila
S. Barbaso by virtue of the Extrajudicial Settlement of Estate
Among Heirs dated February 9, 1982 with Doc. No. 65, Page
No. 14, Book No. II, Series of 1982 before Notary Public Atty.
Brigido I. Tijamo. A copy of the said document is hereto
attached as Annex “C”;

6. That Petitioner kept the Owner’s Duplicate Copy of


Transfer Certificate of Title No. T-16604 for its safekeeping;

5. That recently, Petitioner discovered that Transfer


Certificate of Title No. T-16604 is nowhere to be found. Despite
diligent and earnest efforts in searching it, the same could not
be found anymore so she considered it as lost forever and
beyond recovery. Consequently, petitioner executed an
Affidavit of Loss on February 8, 2021, with Doc. No. 151, Page
No. 32, Book No. 1, Series of 2021, before Notary Public Atty.
Karen S. Tindugan-Perez. A copy of the said document is
attached hereof as Annex “D”;

6. That herein Petitioner had the Affidavit of Loss


annotated in the government’s copy of Transfer Certificate of
Title No. T-16604;

7. That petitioner now wishes that a new owner’s


duplicate copy of Transfer Certificate of Title No. T-16604 will
be issued in lieu of the lost one, under the same faith and
tenor.

PRAYER

WHEREFORE, after due notice and hearing, it is most


respectfully and humbly prayed of this Honorable Court that
judgment be rendered ordering the Register of Deeds for the
Province of Zamboanga del Norte to issue another owner’s
duplicate copy of Transfer Certificate of Title No. T-16604 unto

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herein Petitioner under the same faith and tenor, after
payment of the required legal fees.

September 6, 2021, Dipolog City, Philippines.

LAGUDAS & PEREZ LAW OFFICE


Back Capitol Site, Estaka, Dipolog City

By:
ATTY. EULOGIO L. LAGUDAS, JR.
Counsel for the Petitioner
IBP NO. 131876, 11-04-22
PTR NO. 8327125, 12-29-20
ROLL OF ATTYS. NO. 56396
MCLE COM. NO. VI-0001200 4-14-2022
Back Capitol Site, Estaka, Dipolog City

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