REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH ______, MARIVELES, BATAAN

PETITION FOR ISSUANCE OF

NEW OWNER’S DUPLICATE
OF TCT NO. CLOA-5618 IN
LIEU OF ONE LOST

EDGARDO D. BUENAVENTURA,
Petitioner,
vs. CAD. CASE NO. ________

REGISTER OF DEEDS
FOR BATAAN,
Respondent.
x------------------------------------------x

PETITION

Petitioner, by counsel, avers:

1. Petitioner Edgardo D. Buenaventura is of legal age,

Filipino and a resident of 232 Ilog-Bulo, San Miguel, Bulacan.
Copy of the ID of petitioner is attached as Exhibit A to her
judicial affidavit.

2. Respondent Register of Deeds for Bataan is the

custodian of land titles in Bataan and may be served with
court processes at The Bunker, Capitol Compound, Balanga
City.

3. Petitioner is among the children and heirs of the

late Virgilio R. Buenaventura, Sr. and Lydia D. Buenaventura
who are the registered owners of a parcel of land in Mariveles,
Bataan covered by TCT No. CLOA-5618. Copy of the death
certificates of Virgilio R. Buenaventura, Sr. and Lydia D.
Buenaventura, birth certificate of petitioner and the title are
attached as Exhibits B to E to the judicial affidavit of
petitioner.
 4. Petitioner was in possession of the owner’s
duplicate of the subject title prior to its loss to the exclusion of
others.

5. Petitioner filed an Affidavit of Loss of the owner’s

duplicate of TCT No. CLOA-5618 with the Registry of Deeds for
Bataan in compliance with Section 109 of P.D. No. 1529. Copy
of the affidavit is attached as Exhibit F to the judicial affidavit
of petitioner.

6. The owner’s duplicate of the subject title has never

been pledged or otherwise delivered to any person or entity to
secure the payment or performance of any obligation
whatsoever or for any other purpose, nor any transaction or
document relating to the same presented for or pending
registration in the Registry of Deeds for Balanga, Bataan.

7. The parcel of land covered by the subject title is

declared for taxation purposes and updated in the payment of
real property tax. Copy of the Tax Declaration and receipt are
attached as Exhibits G and H to the judicial affidavit of
petitioner.

8. Petitioner will be presenting himself to prove the

allegations in the petition. Copy of the judicial affidavit of
petitioner with documents in support of the allegations in the
petition is attached as Annex A.

PRAYER

WHEREFORE, it is respectfully prayed that the

Honorable Court render judgment:

1. Declaring the owner’s duplicate of TCT No. CLOA-

5618 that has been lost as null and void; and

2. Ordering the Register of Deeds for Balanga City,

Bataan to issue a new owner’s duplicate of TCT No. CLOA-
5618 in the same terms and conditions as the original thereof.

Other reliefs just and equitable are likewise prayed for.

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Balanga City, ________________.

VINCENT EMMANUEL T. CRUZ

Counsel for the Petitioner
Ground Floor Bataan People’s Center
Capitol Compound, Balanga City
09199963074/vinzcruz@gmail.com
PTR No. 3377096; Balanga City; 01/04/23
IBP No. 275023; Bataan; 01/07/23
MCLE Compliance No. VII-0001751; 12/3/19
Roll No. 49679

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 VERIFICATION AND CERTIFICATION
OF NON-FORUM SHOPPING

I, EDGARDO D. BUENAVENTURA, of legal age, Filipino

and a resident of 232 Ilog-Bulo, San Miguel, Bulacan, after
having been duly sworn to in accordance with law, hereby
depose and say:

1. I am the petitioner in the foregoing Petition which

was not filed to harass, cause unnecessary delay or needlessly
increase the cost of litigation and the factual allegations
therein have evidentiary support.

2. I have caused the preparation and filing of the

foregoing Petition and I have read and understood the
contents thereof and the allegations therein are true and
correct based on authentic records and of my own personal
knowledge.

3. I have not commenced any other action or

proceeding involving the same issues in the Supreme Court,
the Court of Appeals, or any other tribunal or agency, and to
the best of my knowledge, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, or any
other tribunal or agency.

4. If I should thereafter learn that a similar action or

proceeding has been filed or is pending in the Supreme Court,
the Court of Appeals or any other tribunal or agency, I
undertake to report that fact within five (5) days therefrom to
the Honorable Court.
 
IN WITNESS WHEREOF, I have hereunto set my hand
this ____________ at Balanga City.                         

EDGARDO D. BUENAVENTURA

SUBSCRIBED AND SWORN to before me this

__________________at Balanga City by affiant who presented the
following competent proof of identity: Phil. ID No. 2091-0358-
3150-7327

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Doc No. ____;
Page No. ___;
Book No. ___;
Series of 2022.

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