Professional Documents
Culture Documents
LEONILO N. ANTONIO,
Petitioner.
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PETITION
COMES NOW, petitioner, LEONILO N. ANTONIO, through counsel,
unto this Honorable Court, respectfully states:
1.
2.
3.
described as follows1:
1
A certified copy of the technical description of the parcel of land covered by the lost certificate of
title as certified by the Chief of the Technical Services Section of the Department of Environment and
Natural Resources (DENR) is attached herewith as Annex G.
A parcel of land (Lot 7, Blk 6, of the cons. subd. Plan Pcs-13000451, being a portion of the cons. of Lot 2, Psu-172533, Lot 2A (LRC) Psd-232288, Lot 1, (LRC) Psd-72253, & Lot 1, (LRC)
Psd=53634, (LRC) Rec. Nos. N-18807, N-15675, and N-17159),
situated in the Bo. Of Pam[plona, & culasi, Mun. of Las Pias,
Metro Manila, Island of Luzon. xxx containing an area of ONE
HUNDRED SIXTY FIVE (165) SQUARE METERS. xxx.
3.1
3.2
3.3
3.4
Payment of the transfer taxes was then made with the City Treasurer of Las
Pias City (Copies of Official Receipt No. 8023851-J and the corresponding
Confirmation of Payment issued by the Office of the Treasurer is attached as
Annexes C and C-1, respectively).
registered under the name of petitioner and according to the files of the
Registry of Deeds of Las Pias City (RD), a new title was issued under
Transfer Certificate of Title No. T-70380.
A copy of the Tax Declaration for Certificate of Title No. T-16359 is attached herewith as Annex
B.
3
A copy of the Tax Declaration for Certificate of Title No. T-4370 is attached herewith as Annex B-
1.
4
A copy of the Tax Declaration for Certificate of Title No. 104964 is attached herewith as Annex B-
2.
4.
certificate of this title. In fact, the RD does not even have any record that it
was ever released to its registered owner.
5.
6.
requested from Atty. Joel E. Paner (Atty. Paner), Register of Deeds of Las
Pias City, for a copy of TCT No. T-70380.
7.
xxx despite diligent efforts to locate the said title (TCT No. T70380), the same cannot be located from our files along with
Transfer Certificate of Title No. 34193 and the supposed sale
document registered with this Registry for the issuance of said
Transfer Certificate of Title No. 70380.
8.
Atty. Paner also referred in his letter two (2) books of record of
the RD.
First is the Primary Entry Book which would show that there was
indeed a registration of the sale of TCT No. T-34193 executed by Insular Life
in favor of herein petitioner. The second book is the Issuance Book which
would evidence that TCT No. T-34193 was cancelled by virtue of the issuance
of a new title of TCT No. T-70380 with issue date 05 April 1999.
9.
that there was indeed a cancellation of TCT No. T-34193 and an issuance of
TCT No. T-70380 but was also surprised to discover that the RD has lost the
following documents on file with it:
5
6
7
9.1
9.2
9.3
10.
11.
the cancelled certificate of TCT No. T-34193 cannot be located from the
available records of the RD8.
12.
From the foregoing, it is evident that the original copy of TCT No.
T-70380 on file with the RD and the unreleased owners duplicate copy of the
same title cannot be located and are deemed lost.
13.
14.
15.
TCT No. T-70380 was in full force and effect at the time it was
16.
lost.
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18.
by the Official Receipts from 2007 to 2011 issued by the City Treasurers
Office of Las Pias City. (A copy of the Official Receipts for 2007, 2008, 2009,
2010, 2011 and 2012 for TCT No. T-70380 is attached as Annexes G, G1, G-2, G-3, G-4 and G-5.)
19.
other instruments affecting the property by any person or entity which have
been filed or is pending registration with the RD affecting said parcel of land
as of this date.
20.
herewith:
20.1 The technical description of the parcel of land covered by
the lost certificate of title as certified by the Chief of the
Technical Services Section of the Department of Environment
and Natural Resources (DENR) (A copy of certified technical
description is attached as Annex H.); and
20.2 The sepia film of the subject property certified by the
Chief of Surveys Division of the DENR as an exact reproduction
of the film on file at the Land Survey Records Section (A copy of
the sepia film is attached as Annex H-1.).
RELIEF
WHEREFORE, premises considered, it is respectfully prayed that this
Honorable Court:
1) order that the original owners duplicate copy of Transfer
Certificate of Title No. T-70380 lost in the possession of the
Registry of Deeds of Las Pias City be reconstituted on the basis
of its Primary Entry Book and Issuance Book and the Deed of
Absolute Sale between Insular Life and petitioner; and
2) direct the Register of Deeds of Las Pias City to issue an
Owners Duplicate Certificate of Transfer Certificate of Title No.
T-70380 upon payment of the prescribed legal fees.
Other relief, just and equitable under the premises, are likewise prayed
for.
Muntinlupa City for Las Pias City, 19 September 2012.