Republic of the Philippines

First Judicial Region

REGIONAL TRIAL COURT
BRANCH ____
San Fernando City, La Union

IN RE: PETITION FOR ISSUANCE

OF NEW OWNERS COPY OF
ORIGINAL CERTIFICATE OF
TITLE No. CLOA-1023

SIMPLICIO N. FLORES,
Petitioner,
LRC CASE NO. ______
- versus

REGISTER OF DEEDS OF LA
UNION and ALL PERSONS WHO
MAY BE AFFECTED THEREBY,
Respondents.
x---------------------------x

PETITION
COMES NOW Petitioner through the undersigned Public Attorney,
unto this Honorable Court, respectfully avers:

1. That petitioner is of legal age, married, Filipino citizen and residing

at Lioac Sur, Naguilian, La Union, Philippines where he may be
served with summons, notices and other court processes;

2. That respondent Register of Deeds of La Union is a state agency

tasked in the registration of properties in the province of La Union,
with office address at Government Center, Sevilla, San Fernando
City, La Union, Philippines where he may be served with summons,
notices and other court processes;

3. That Petitioner is the owner of a parcel of land located at Brgy.

Nagyubuyuban, San Fernando City, La Union, Philippines declared
under Original Certificate of Title No. CLOA-1023, more particularly
described as:

A parcel of land Lot 14820, being a portion of San Fernando

Cadastre, situated at Barangay Nagyubuyuban, Municipality
of San Fernando, Province of La Union, Island of Luzon,
PETITION
LRC Case No. ____
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 bounded on the N., points 1-2 by Lot 14819, on the E., points
2-3 by Lot 14843, on the S., points 3-4 by Lot 14821, on the
W., points 4-1 by creek, all by Cad.539-D, San Fernando
Cadastre.

- xxx -

Containing an area of TWENTY THREE THOUSAND FIVE

HUNDRED NINETEEN (23,519) square meters more or
less.

4. That the above described property was awarded to petitioner

pursuant to a Certificate of Land Ownership Award with number
00263263 issued by the Department of Agrarian Reform last October
16, 2002 and the same have been titled in his name covered by
Original Certificate of Title No. CLOA-1023 with Respondent
Register of Deeds;

5. In October 2009, petitioners residence was inundated by Typhoon

Pepeng and thereby destroying and taking away everything in their
house including the Owners Copy of the Original Certificate of Title
No. CLOA-1023 covering the above-described property;

6. That despite diligent search and efforts to locate said Owners Copy
of the Original Certificate of Title No. CLOA-1023 covering the
above-described property, petitioner could not find the same such
that he now believes that said certificate of title is lost beyond
recovery;

7. That petitioner has not encumbered or mortgaged the above-

described parcel of land and that said copy of Original Certificate of
Title No. CLOA-1023 was not delivered to any person or entity to
secure payment or in performance of any obligation whatsoever;

8. That petitioner executed an Affidavit of Loss and had the same

registered and annotated at the Original Certificate of Title on file
with the Respondent Register of Deeds, a copy is hereto attached as
Annex A; and

9. That attached herewith as Annex B is a certified copy of the

Original Certificate of Title No. CLOA-1023 without any
encumbrance and with the annotation of the Affidavit of Loss (Annex
A) executed by petitioner.

PRAYER

PETITION
LRC Case No. ____
Page 2 of 4
 WHEREFORE, premises considered, it is most respectfully prayed
that after due notice and hearing, an order be issued by this Honorable
Court declaring the owners copy of Transfer Certificate of Title No. T-
14926 which was lost, as null and void and of no force and effect and to
order and direct the Register of Deeds of La Union, after payment of
petitioner of the fees prescribed by law, to issue in lieu thereof new owners
duplicate certificate which shall in all respects be entitled to like faith and
credit as the original duplicate, in accordance with Section 109 of Act No.
496, as amended by PD 1529.

Other reliefs just and equitable under the premises are likewise
prayed for.

RESPECTFULLY SUBMITTED this June 21, 2017 at San Fernando

City, La Union, Philippines.

PUBLIC ATTORNEYS OFFICE

San Fernando City (LU) District Office
Justice Hall, Sevilla
San Fernando City, La Union
Counsel for Petitioner
by:

GILBERT R. HUFANA
Public Attorney II
Roll No. 61392; March 27, 2012
IBP No. 1020149; January 8, 2016; IBP La Union Chapter
MCLE Compliance No. V-0002509 (Valid until 04/14/2019)

JEFFREY M. AGTARAP
Public Attorney II/OIC- SFC,LU DO
Roll No. 55673; May 2, 2008; Manila
IBP No. 1003824; January 8, 2016; IBP Baguio-Benguet Chapter
MCLE Compliance No. V-0005062; December 22, 2014

Republic of the Philippines)

Province of La Union ) S.S

PETITION
LRC Case No. ____
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City of San Fernando )

VERIFICATION AND CERTIFICATION

AGAINST FORUM-SHOPPING
I, SIMPLICIO N. FLORES, married, of legal age, Filipino and a
resident of Barangay Lioac Sur, Naguilian, La Union, Philippines, after
having been duly sworn to in accordance with law, do hereby depose and
state that:

1. I am the Petitioner in the above captioned-case and I have caused

the preparation of the foregoing Petition, the contents of which are
supplied by me and are all true and correct to the best of my
personal knowledge, information and belief, the allegations
therein are true and correct and based on authentic documents at
hand;

2. I certify that neither have I not commenced nor is there any

Petition of similar nature before any court, tribunal or quasi-
judicial agency pending thereat; and that if I should hereafter
learn that the same or similar Petition has been filed or is pending
in any court, tribunal or quasi-judicial agency, I shall report the
fact within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand this June 21,

2017 in San Fernando City, La Union, Philippines.

SIMPLICIO N. FLORES
Affiant

SUBSCRIBED AND SWORN to before this June 21, 2017 at San

Fernando City, La Union, Philippines.

Copy furnished:

OFFICE OF THE CITY PROSECUTOR REGISTER OF DEEDS OF LA UNION

Justice Hall, Sevilla Government Center, Sevilla
San Fernando City, La Union San Fernando City, La Union

PETITION
LRC Case No. ____
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