Republic of the Philippines

REGIONAL TRIAL COURT

Third Judicial Region
Branch ____
Tarlac City

IN RE: PETITION FOR ISSUANCE

OF SECOND OWNER’S
DUPLICATE COPY OF
TRANSFER CERTIFICATE OF
TITLE NO. 80768 REGISTERED IN
THE NAME OF REBECCA S.
AGDEPPA

REBECCA S. AGDEPPA
LRC CASE NO. _____
represented by her attorney-in-fact,
MA. LORELEI A. FLORES
Petitioner,

- versus -

THE REGISTRY OF DEEDS FOR

THE PROVINCE OF TARLAC,
Respondent.
x---------------------------------------------x

PETITION
PETITIONER, through counsel, unto this Honorable Court,
most respectfully states that:

1. Petitioner is of legal age, Filipino citizen and a resident of

__________________. She is herein represented by her
attorney-in-fact, MA. LORELEI A. FLORES, of legal age,
Filipino citizen and a resident of Phase K1, B4, L7 Francisco
Homes, Yakal, San Jose Del Monte City, Bulacan. A copy of
the Special Power of Attorney that petitioner has executed
in favor of Ma. Lorelei A. Flores is hereto attached as
Annex “A” and made an integral part hereof;

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2. Respondent Registrar of Deeds for the Province of Tarlac
being the repository of all deeds and titles of property. Its
official address is at Registry of Deeds Building, Tarlac
City, where they may be served with summons and other
processes of this Honorable Court;

3. REBECCA S. AGDEPPA is the registered owner of a parcel

of land covered and described under Transfer Certificate of
Title (TCT) No. 80768. The Certified True Electronic Copy
of TCT No. 80768 and its Tax Declaration showing that
Veronica T. Castro is the registered owner thereof, are
hereto attached as Annex “B” and Annex “C”,
respectively, and made integral parts hereof;

4. TCT No. 80768 contains an area of Five Hundred Twenty

Seven (527) square meters, more or less. The parcel of land
covered and described under the said Transfer Certificate
of Title is situated in Barangay ___________, Gerona,
Tarlac;

5. The original copy of TCT No. 80768 is existing and on file

in the Registry of Deeds of Tarlac as evidenced by the fact
that the petitioner was able to obtain the above-mentioned
certified true electronic copy of the said title at the Registry
of Deeds of Tarlac;

6. As to the original owner’s duplicate copy of TCT No.

80768, petitioner turned over and entrusted the same to his
attorney-in-fact in this case, Ma. Lorelei A. Flores, for
proper safekeeping. Ma. Lorelei A. Flores then kept the
owner’s duplicate copy of TCT No. 80768 inside a cabinet
of their house. Recently, Ma. Lorelei A. Flores conducted a
general cleaning at their house and found out that the
owner’s duplicate copy of TCT No. 80768 is already
missing. He exerted diligent efforts to locate and recover
the same but to no avail. Thus, he executed an Affidavit of
Loss which is hereto attached as Annex “D” and made an
integral part hereof;

7. The original owner’s duplicate copy of TCT No. 80768 is

still in full force and effect at the time that it was lost;

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 8. The parcel of land involved in this petition is previously
mortgaged with the Rural Bank of Ramos Inc., however,
the said mortgage has already been cancelled as evidenced
by a Cancellation and Discharge of Mortgage which is
hereto-attached as Annex “E” and made an integral part
hereof;

9. The parcel of land involved in this petition is free from all

liens and encumbrances of any kind, and there is no deed
or instrument affecting the property which has been
presented or pending registration to this date in the
Registry of Deeds of Tarlac;

10. Also, the original owner’s duplicate copy of TCT No. 80768
was not given or delivered to anybody to secure the
payment of any obligation or undertaking;

11. The Real Property Tax on the parcel of land covered and
described under TCT No. 80768 has been paid up to the
current year as evidenced by Official Receipt issued by the
Municipal Treasurer’s Office of Gerona, Tarlac which is
hereto attached as Annex “F” and made an integral hereof;

12. Petitioner’s attorney-in-fact, Ma. Lorelei A. Flores, will

testify on the material allegations of this petition and that
the petitioner is entitled to the reliefs prayed for herein. He
has executed a Judicial Affidavit which hereto attached as
Annex “G” and made an integral part hereof.

PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed unto this Honorable Court that after due notice and hearing,
an order be issued:

1. Declaring the owner’s duplicate copy of TCT No. 80768

previously issued as lost, null and void, and without any
legal effect whatsoever; and

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 2. Directing the Registry of Deeds for the Province of Tarlac
to register the second owner’s duplicate copy of TCT No.
80768 which will be issued.

Other reliefs just and equitable under the circumstances are

likewise prayed for.

Respectfully submitted,
Tarlac City, ______________ 2022.

ATTY. RONILO U. BORJA

Counsel for the Petitioner
Block 2, Champaca Street, Barangay San Vicente
2300 Tarlac City, Tarlac Province
Roll of Attorneys No. 77835
IBP receipt No. 234487; 18 July 2022; Tarlac
PTR no. 5223857; 19 September 2022; Tarlac City
MCLE 8th COMPLIANCE / Admitted to Bar May 11,
2022
ronilo.borjalaw@gmail.com

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Republic of the Philippines s.s.
Tarlac City

VERIFICATION AND CERTIFICATION

AGAINST FORUM SHOPPING

I, MA. LORELEI A. FLORES, of legal age, Filipino, and a

resident of Phase K1, B4, L7 Francisco Homes, Yakal, San Jose Del
Monte City, Bulacan, after having been duly sworn to in accordance
with law, depose and say:

1. I am the attorney-in-fact of the Petitioner in the above-

entitled case;

2. I have caused the preparation of the foregoing Petition;

3. I have read the foregoing Petition and the allegations stated

therein are true and correct based on my personal
knowledge, or based on authentic documents;

4. The Petition is not filed to harass, cause unnecessary delay

or needlessly increase the cost of litigation;

5. The factual allegations in the Petition have evidentiary

support, or if specifically so identified, will likewise have
evidentiary support after a reasonable opportunity for
discovery;

6. I have not commenced any action or filed any claim

involving the same issues in any court, tribunal or quasi-
judicial agency and, to the best of my knowledge, no such
other action or claim is pending therein;

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 7. Should I thereafter learn that the same or similar action or
claim has been filed or is pending, I undertake to report
such fact within five (5) calendar days therefrom to this
Honorable Court wherein this Petition has been filed.

In witness hereof, I have hereunto set my hand this __ day of

_____________ at Tarlac City.

MA. LORELEI A. FLORES

Affiant

Subscribed and sworn to before me this __ day of ___________

at Tarlac City. Affiant, whom I identified through her
__________________________ bearing her photograph and signature,
signed this document in my presence and avowed under penalty of
law to the whole truth of the contents of the foregoing document.

Doc. No. ________;

Page No.________;
Book No.________;
Series of 2023.

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