Vous êtes sur la page 1sur 2

Habib U.

Simban
4L Arellano

Republic of the Philippines


REGIONAL TRIAL COURT
12TH Judicial Region
Branch 1, Iligan City

IN RE: PETITION FOR ISSUANCE OF


NEW DUPLICATE CERTIFICATE OF
TITLE NO. 123456 LRC No. 123456

JOSE PALMA
Register of Deeds
Iligan City
Defendant

x----------------------------------------------x

ANSWER
Defendant through the undersigned counsel, and unto this Honorable Court,
respectfully alleges that:

1. On March 1, 2019, petitioner filed before this Honorable Court a Petition for
Replacement of her Duplicate Certificate of Title No. 123456;
2. Petitioner alleges in his Petition that pending registration of the said Duplicate
Certificate of Title and other documents, and while same were in the possession
and custody of the office of the defendant, the building in which was housed said
office was burned to the ground, together with all its records and papers, and the
said papers were not among those salvaged from the fire;
3. However, Defendant strongly disaffirm the replacement of said Duplicate
Certificate of Title since the building was not actually caught by fire;
4. The said building was just transferred from Mahayahay, Iligan City to Tominobo,
Iligan City;
5. Further, Petitioner’s request of asking for replacement of said title was tainted of
fraud since the Petitioner’s title was not among the titles recorded by the
Defendant and Petitioner’s actuation was to secure a title for himself even he
was not the real owner of the property.
Habib U. Simban
4L Arellano

WHEREFORE, pursuant to law, and in view of the facts stated hereinabove, it is


respectfully prayed that Petitioner’s petition for Replacement of Duplicate Certificate of
Title be DISMISSED and the said Duplicate of Title shall not be replaced in his favor.

Iligan City, April 13, 2019.

ATTY. TRES CUATRO


Counsel for Defendant
Mahayahay, Iligan City
IBP No. 3333333; 01/10/19 - Iligan
PTR No. 2222222; 01/10/19 – Iligan
Roll No. 333333; 05/06/19
MCLE No. I-66666; 01/10/19

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES)


CITY OF ILIGAN ) S.S.

I, Jose Palma, Filipino, of legal age residing at Purok 5, Brgy Saray, Iligan City,
after being sworn to in accordance with law, deposes and says that:

1. I am the petitioner in the above-entitled Petition;


2. The facts stated in the above Petition are true and correct to the best of my
knowledge and authentic records;
3. I have not commenced any action involving the same issue in court, tribunal or
quasi-judicial agency and, to the best of my knowledge, no such other action is
pending in them; and
4. If I should learn that the same or similar action has been filed or is pending after
its filing, I shall report that fact within five (5) days from notice to the court or
where the petition has been filed.

March 1, 2019. Iligan City.

JOSE PALMA

Copy furnished:

ATTY. UNO DOS


Counsel for Plaintiff
Unit 5, Solana District, Iligan

Vous aimerez peut-être aussi