REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
OFFICE OF THE CLERK OF COURT & EX-OFFICIO SHERIFF
QUEZON CITY

JIMMY G. LORENZO,
Petitioner-Mortgagee,

– versus – EJF No. _____________

For: Extra-judicial Foreclosure
of Mortgage under Act. No.
3135, as amended
(TCT No. 005-2017011841)

SPS. NOEL M. REYES &

ARSENIA B. REYES ,
Mortgagors.
x - - - - - -- - - - - - - - - - - - - - - - - - - - - -x

PETITION FOR EXTRA-JUDICIAL FORECLOSURE

OF REAL ESTATE MORTGAGE

EX-OFFICIO SHERIFF
Regional Trial Court
Quezon City

Greetings:

We hereby deliver to you as Annex “A” the attached certified

machine copy of the Real Estate Mortgage dated 24 July 2017 which
was executed by Sps. NOEL M. REYES and ARSENIA B. REYES, as
MORTGAGORS, Filipino citizens, of legal age, and a resident of No.
36 Redview Avenue, Greenview Royale Executive Village, Tandang
Sora, Quezon City, in favor of JIMMY G. LORENZO, as
MORTAGEE, Filipino citizen, of legal age, and a resident of No. 88
Scout Barrios, Barangay South Triangle, Quezon City, over a parcel of
land, together with all the improvements existing thereon, registered
in the name of Mortgagors and declared for Taxation purposes under
Tax Declaration No. F-046-05277 and D-046-22857, hereinafter
referrred to as “PROPERTY” and more particularly described as
follows:
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TRANSFER CERTIFICATE OF TITLE NO. . 005-2017011841)

Lot No. , PSD- ----------------

“-------------------------------------------------------------------
--------------------------------------------------------------------
‘.

xxxx xxxx

containing an area of ONE HUNDRED FIFTY SIX

SQUARE METERS AND TEN SQUARE DECIMETERS
(156.10), more or less.

To secure the payment of the indebtedness and/or obligation/s

of the MORTGAGOR/S.

We hereby request you to foreclose the said Real Estate

Mortgage [Annex “A”] hereof, and in support thereof, we state the
following;

1. The terms and conditions of Real Estate Mortgage [Annex “A”]

has never been changed or modified, whether tacitly or
expressly, by any agreement made after the execution thereof;

2. The principal obligation secured by said mortgage which has

become overdue as of 31 September 2017 has remained unpaid
up to the present despite repeated demands in violation of the
terms of the mortgage deed;

3. The Mortgagor has not executed a second or subsequent

mortgage over the mortgaged property and the improvement
thereon with the knowledge and consent of the Mortgagee;

4. To the best of our knowledge, the Mortgaged property is

subject to no prior mortgage or any lien whatsoever, and is now
in the possession and full control of the above-named
Mortgagor;

5. Under the terms and conditions of the Real Estate Mortgage,

the Mortgagee is entitled to extra-judicially foreclose the
mortgaged property;

6. By the terms and conditions of the Real Estate Mortgage

referred to above, the principal obligation of the Mortgagor
which has become overdue as of 31 September, 2017 is in the
amount of THREE MILLION EIGHT HUNDRED

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 TWENTY FIVE THOUSAND EIGHT HUNDRED
SEVENTY EIGHT PESOS AND NINETY CENTAVOES
ONLY (P 3,825,878.90), inclusive of past due interest,
penalty charge and service charge but exclusive of Attorney’s
Fee representing 10% of the total obligation due, other charges
and expenses of foreclosure.

Also enclosed and made integral parts of this petition are:

a) Demand Letter , dated 20 November 2017, as Annex “B”

b) Registry Return Card as Annex “C”
c) Copy of Transfer Certificate of Title No. 004-2015011841 as
Annex “D”
d) Copy of Tax Declaration of Land and Building as Annexes “E”
and ‘F”, respectively.
e) Statement of Account as Annex “G”.

Wherefore, the MORTGAGEE most respectfully requests the

Honorable Clerk of Court and Ex-Officio Sheriff of the Regional Trial
Court of Quezon City to take possession and foreclose extra-judicially
and sell at public auction the above-mentioned Real Property
together with all the improvements thereon, described in the Real
Estate Mortgage [Annex “A”] in accordance with law, particularly the
provision of Act No. 3135, as amended by Act No. 1508 and in
consonance with Republic Act 386.

Please furnish us and the Mortgagor/s with copies of your Notice

of Sale at least fifteen (15) days before the date of sale.

Quezon City, 2 February 2018.

TINA A. PANER
Counsel for the Petitioner-Mortgagee

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