REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
Branch _____
Rosario, Batangas

IN RE: PETITION FOR RECONSTITUTION

OF THE ORIGINAL COPY OF THE
TRANSFER CERTIFICATE OF TITLE
NO. T-39701 IN THE REGISTRY OF
DEEDS OF BATANGAS PROVINCE

SPEC PROC. CASE NO. ___________

APEX BANK (RURAL BANK OF LIPA CITY,

INCORPORATED),
Represented herein by
___________________________,
Petitioner.
x----------------------------------x

PETITION

Petitioner, by undersigned counsel, unto this Honorable Court,

most respectfully states that:

1. Petitioner is a corporation duly organized and existing under

Philippine laws with principal office address at Poblacion, Lipa City.
Petitioner is represented herein by __________________. Copy of the
Secretary’s Certificate is hereto attached and made an integral part
hereof as Annex “A”.

2. Petitioner is the registered mortgagee of a parcel of land owner

of a parcel of land located at Mavalor, Rosario, Batangas, covered by and
described in Transfer Certificate of Title No. T-39701, the technical
description of the said parcel of land being found in evidence by:

TRANSFER CERTIFICATE OF TITLE NO. T-39701

“A parcel of land (Lot No.2 plan Psu-106034, Sheet

No. 1 G.L.R.O. Record No 53675), with the improvements
and building thereon, situated in the Barrio of Mabaloar,
Municipality of Rosario, Province of Batangas. Bounded
on the NE., by a trail; On the SE., by property of Albina
Escamillas, on the SW., by property of Angelo Limbag;

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 and on the NE., by property of Eulalio de Villa. x x x x x
containing an area of SEVEN THOUSAND TWO HUNDRED
FIFTY SEVEN (7,257) SQUARE METERS, more or less from
B.L.L.M. No. 1;
thence S. 10 deg. 29’E., 72.24 m. to point 2;
thence S. 83 deg. 18’W., ____ m to point 3;
thence N. 2 deg. 43’W., 75. 32 m. to point 4;
thence N. 85 deg. 25’E __m. to point of”

Copy of the Transfer Certificate of Title is hereto attached and

made an integral part hereof as Annex “B”.

3. The original of the aforesaid Transfer Certificate of Title on file

with the Registry of Deeds of Batangas City was lost or destroyed
sometime in ________________. Copy of the Affidavit is hereto attached
and made an integral part hereof as Annex “C”.

4. No deed or other instrument affecting the property has been

presented for registration, or if there be any, the nature thereof, the date
of its presentation, as well as the names of the parties and whether the
registration of such deed or instrument is still pending accomplishments.

5. The owner’s duplicate certificate is in due form without any

intentional alteration or erasures.

6. The certificate of title is not the subject of litigation or

investigation, administrative or judicial regarding its genuineness or
due execution or issuance.

7. The original certificate of title was in full force and effect at

the time it was lost or destroyed.

8. The certificate of title is covered by Tax Declaration regularly

issued by the Assessor’s Office. A copy of the Declaration of Real
Property No. ______________________ is hereto attached and made an
integral part hereof as Annex “D”.

9. The real estate taxes have been fully paid up for at least two
(2) years prior to the filing of the petition for reconstitution. A copy of
the Certification from the Office of the Municipal Treasurer is hereto
attached as Annex “E” and made an integral part hereof.

10. The corresponding owner’s duplicate certificate of said

Transfer Certificate of Title No. T-39701 is in the possession of the
petitioner.

11. The adjoining landowners and their addresses are as follows:

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 North – _____________________

East – _____________________

South – _____________________

West – _____________________

PREMISES CONSIDERED, it is respectfully prayed that the original of

the third sheet/additional sheet of Transfer Certificate of Title No. T-
39701 which was lost or destroyed in the files of the said Registry of
Deeds for Batangas Province be ordered reconstituted on the basis of
the owner’s duplicate certificate of title and in accordance with
Republic Act No. 26.

Batangas City, October 14, 2016.

ROBERTO IÑIGO D. SANCHEZ

Counsel for Petitioner
PTR No. 2576992 01.14.2016 Bats. City
IBP No. 1011277 01.20.2016 Bats. City
Roll No. 61644
MCLE Compliance Certificate No. V-0004482
Tel. No. (043)702-2783; Mobile No. 0918-3752291
ridslawoffice@gmail.com

VERIFICATION AND CERTIFICATION

I, __________________________, of legal age, with office address at

Poblacion, Lipa City, after having been sworn to in accordance with
law, hereby depose and state:

1. That I am the legal representative of the petitioner in the

above-captioned petition;

2. That I caused the preparation and filing of the foregoing

petition and certify that I have read and understood the same and
that the averments contained therein are true and correct of my own
knowledge and based on authentic documents;

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 3. That no other action or proceedings involving the same
issues has been hereto commenced any action/proceeding involving
the matters/issues taken up in the present petition with the Supreme
Court/Court of Appeals/Regional Trial Court, or any other tribunal
Court, tribunal or agency other than this present petition, and if it
should be learned later on that a similar action or proceeding has
been filed or is so pending, the undersigned undertakes to report
the fact within five (5) days therefrom to this Court.

IN TRUTH HEREOF, I have hereunto set my hands this

______________ at Batangas City.

__________________________________________
Affiant
ID No. ____________________

SUBSCRIBED AND SWORN to before me this _________________

at Batangas City, affiant exhibiting to me his identifying document
stated above.

NOTARY PUBLIC

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2016.