Republic of the Philippines

REGIONAL TRIAL COURT

11
th
Judicial Region
Branch ___
Tagum City, Davao del Norte



IN RE: PETITION FOR ISSUANCE LRC. CASE # ___________
OF NEW CERTIFICATE OF TITLE
IN LIEU OF THE LOST ONE FOR: Reconstitution of
Lost Title
SPS. MELANIO TREBAJO, JR. and
ADELUISA A. TREBAJO
Duly represented by MEDARDO Q.
TREBAJO
As Attorney-in-Fact
Petitioners,

-versus-

REGISTRY OF DEEDS FOR THE
PROVINCE OF DAVAO
Defendant.
x--------------------------------------x


PETITION FOR RECONSTITUTION
OF LOST TITLE

PETITIONERS, assisted by the undersigned counsel, most respectfully states:

1. That petitioners are both of legal age, Filipinos, married to each other and
duly represented in this petition by MEDARDO Q. TREBAJO, as their
Attorney-in-Fact, per Special Power of Attorney notarized before Notary
Public ANTONIO M. BRAGANZA of California, Photocopy of the same is hereto
attached and marked as Annex A;

2. That the petitioners are the owners of parcel of land covered by Transfer of
Certificate Title No. T-41510, consisting an area of ONE HUNDRED
EIGHTY (180) SQUARE METERS, more or less, situated at Visayan Village,
Tagum City, Davao del Norte, of Registry of Deeds for the Province of Davao
del Norte. Certified True Copy of Transfer Certificate of Title is hereto
attached and marked as Annex B;

3. That, unfortunately, while the Owners Duplicate Copy of Transfer Certificate
of Title No. T-41510 in the name of Petitioners was in their possession and
custody, thru inadvertence it was lost and despite earnest efforts exerted to
locate the same, but, of no avail. Photostat copy of the Affidavit of Loss duly
authenticated by the Deeds for the Province of Davao del Norte is hereto
attached as Annex C;

4. That said Transfer of Certificate of Title has never been pledged or otherwise
delivered to any person or entity to guarantee any obligation or for any other
purpose and that said title is intact with the Office of the Registry of Deeds
for the Province of Davao del Norte, copy of the certification is hereto
attached and marked as Annex D;

5. That the taxes of the subject parcel of land have been duly paid, copy of the
Tax Clearance is hereto attached as Annex E;

6. That subject land is not subject to any pending case. Copy of the Certification
of No Pending Case is hereto attached as Annex F;

7. That this petition is filed in good faith and not to circumvent any law.


PRAYER


WHEREFORE, petitioners respectfully pray of this Honorable Court to
declare null and void the owners duplicate of Transfer Certificate of Title No. T-
41510, which has been lost and to order and direct the Registry of Deeds of the
Province of Davao del Norte after payment of the fees prescribed by law, to issue in
lieu thereof a new owners duplicate Transfer Certificate of Title No. T-41510 which
shall be, in all respect, entitled to like faith and credit as the original duplicate in
accordance with section 109 of Act. 496, as amended by Presidential Decree No.
1529 otherwise known as Property Registration Decree.

PETITIONERS, pray for such other relief/s just and or equitable under the
premises.

Tagum City, Philippines, ___________________.




SPS. MELANIO TREBAJO, JR. and ADELUISA A. TREBAJO




Duly represented by: MEDARDO Q. TREBAJO
As Attorney-in-Fact




Assisted by:


ATTY. PLACIDO R. ALCOMENDRAS, III
Counsel for the Petitioners
Door 6, Sevillano Bldg., Km. 56, National Highway,
Tagum City, Davao del Norte
MCLE Comp. No. III-0002791/3-24-2009
PTR No. 4827702/1-4-2013
IBP No. 851444/11-26-2012
TIN: 194-391-529
Roll No. 42826


Republic of the Philippines )
Tagum City )
x-------------------------------x


VERIFICATION AND CERTIFICATION OF
NON-FORUM SHOPPING

I, MEDARDO Q. TREBAJO, of legal age, married, Filipino and a resident
of 4236 Luzvimin Mel Village, Magugpo West, Tagum City, Davao del Norte,
after having been sworn to in accordance with law do hereby depose and
state:

1. That I am the Attorney-In-Fact of the abovementioned case, per
Special Power of Attorney notarized before ANTONIO M.
BRAGANZA, Notary Public for and in California;

2. That all the contents and allegations thereat are true and correct to
my own knowledge and belief an the documents therewith attached
are based on authentic records;

3. That I have not commenced in any other proceedings or actions
involving the same issues in this case in the Supreme Court, the
Court of Appeals or any other tribunal or agency;

4. That 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;

5. That if I should 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 the same within
Five (5) days from knowledge hereof to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this
_______ day of _______________ at Tagum City, Davao del Norte.



MEDARDO Q. TREBAJO
Affiant


SUBSCRIBED AND SWORN TO BEFORE ME. Affiant exhibiting to me
her ____________________________________________.