Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch 12, Laoag City

In Re: PETITION FOR THE RE-

ISSUANCE OF A SECOND
OWNER’S DUPLICATE COPY OF
TRANSFER OF CERTIFICATES OF
TITLE

JOVIC LA PEÑA CAD Case No.101101

Petitioner, LRC Record No. 3654
Lot No. 09851
-versus- TCT Nos. T-33454 and
T-33457
Laoag Cadastre
THE REGISTER OF DEEDS,
Represented by ATTY AUGUSTUS
LUCAS, in his capacity as Register
of Deeds of Laoag City
Respondent,
x---------------------------------------------------------------------x

FORMAL OFFER OF DOCUMENTARY EVIDENCE

Petitioner by the undersigned counsel and unto this Honorable

Court, most respectfully offers in evidence the following documentary
exhibits for the above titled case, to wit:

EXHIBITS DESCRIPTION PURPOSE

A The Petition consisting of 6 To prove that a petition
pages. has been filed before the
Honorable Court.

A–4 Name and Signature of the To prove that the Petition

Counsel for the Petitioner has been signed by the
on the 4th page. Counsel of the Petitioner.

A–6 Name and Signature of the To prove that the

Petitioner 5 page.
th
Petitioner signed and
executed the Certification
and Verification Against
Non-Forum Shopping.
B Electronic Copy of the
Transfer Certificate of Title
No. T-33454 consisting of
5 Pages.
B-2 Page 3 of the Electronic
Copy of the Transfer
Certificate of Title No. T-
33454; Memorandum of
Encumberances
B-3 Page 3 of the Electronic
Copy of the Transfer
Certificate of Title No. T-
33454; Memorandum of
Encumberances
B-4 Page 5 of the Electronic
Copy of the Transfer
Certificate of Title No. T-
33454. Memorandum of
Encumbrance bearing an
annotation of such
submission of Affidavit of
Loss of the Transfer of
Certificate of Title thru a
document dated dated 7
February 2018 notarized as
Doc. No. 162, Page No. 33,
and Book No. XXVI, Series
of 2018 by Atty Ernielineo
B. Labrador
C Electronic Copy of the
Transfer Certificate of Title
No. T-33457 consisting of
5 Pages.
To prove that JOVIC LA
PEÑA is one of the
registered co-owner of
the lot covered by TCT.
No. 33454
To prove that the TCT
bears no annotation of
being pledged or
otherwise delivered to
any person or entity to
secure the payment of
any obligation or for any
other purposes
To prove that the TCT
bears no annotation of
being pledged or
otherwise delivered to
any person or entity to
secure the payment of
any obligation or for any
other purposes
To prove that Petitioner
notified the Register of
Deeds of Laoag City by
submitting a copy of the
Affidavit of Loss to the
said office.
To prove that JOVIC LA
PEÑA is one of the
registered co-owner of
the lot covered by TCT.
No. 33457.
C–2 Page 3 of the Electronic
Copy of the Transfer
Certificate of Title No. T-
33457; Memorandum of
Encumberances
To prove that the TCT
bears no annotation of
being pledged or
otherwise delivered to
any person or entity to
secure the payment of
any obligation or for any
other purposes

C–3 Page 3 of the Electronic To prove that the TCT

Copy of the Transfer
Certificate of Title No. T-
33454; Memorandum of
Encumberances
bears no annotation of
being pledged or
otherwise delivered to
any person or entity to
secure the payment of
any obligation or for any
other purposes

C-4 Page 5 of the Electronic To prove that Petitioner

Copy of the Transfer notified the Register of
Certificate of Title No. T- Deeds of Laoag City by
33457. Memorandum of submitting a copy of the
Encumbrance bearing an Affidavit of Loss to the
annotation of such said office.
submission of Affidavit of
Loss of the Transfer of
Certificate of Title thru a
document dated dated 7
February 2018 notarized as
Doc. No. 163, Page No. 33,
and Book No. XXVI, Series
of 2018 by Atty Ernielineo
B. Labrador

D Birth Certificate of JOVIC To prove that VICTORINA

LA PEÑA LUCAS GUERRERO, one
of the registered co-
owner of the lot covered
by TCT T33454 is the
mother of the petitioner

E Death Certificate of To prove that VICTORINA

VICTORINA LUCAS LUCAS GUERRERO, one
GUERRERO of the co-owner of the lot
covered by TCT T33454 is
dead.
F Birth Certificate of GILDA To prove that GILDA L. LA
L. LA PEÑA PEÑA, one of the co-
owners of the lot covered
by TCT T-33454 and T-
33457 is born from
VICTORINA LUCAS
GUERRERO, and thus the
sister of the Petitioner.

G Special Power of Attorney To prove that the

constituted between Petitioner has been
GILDA L. LA PEÑA and the authorized by her
Petitioner consisting of 2 registered co-owner to
pages. file the petition.

G-3 Signature and Name of To prove that GILDA L. LA

GILDA L. LA PEÑA on the PEÑA signed the SPA
2nd page. constituting the Petitioner
as her agent.

G- 4 Signature and Name of the To prove that Petitioner

Petitioner on the 2nd page. signed the SPA.

H Genuine and true copy of To prove the loss of the

the Affidavit of Loss TCT T-33457 and that the
executed by the Petitioner Petitioner executed an
covering TCT T-33457 on 7 affidavit of loss covering
February 2018 and the same TCT.
notarized as Doc. No. 163,
Page No. 33, and Book No.
XXVI, Series of 2018,
consisting of 2 pages.

H-1 Rubber Stamp Mark placed To prove that the

by the receiving officer of Petitioner caused the
the Registry of Deeds annotation of the Affidavit
Laoag City bearing Control of Loss at the Electronic
No. 2018000150, dated 7 Copy of TCT 33457.
February 2018, received at
1:37 PM and signed by the
receiving officer, on the 1st
Page.
H-3 Signature and the printed To prove that the
name of the Petitioner on petitioner signed the
the 2nd Page. Affidavit of Loss covering
TCT – 33457.

H-4 Rubber Stamp Mark To prove that the Affidavit

certifying that the Affidavit of Loss covering TCT –
of Loss has been duly 33457 has been duly
registered in the Laoag City registered in the Register
Registry of Deeds, bearing of Deeds, Laoag City.
the signature of ATTY.
AUGUSTUS A. LUCAS, on
the second page.

I Genuine and true copy of To prove the loss of the

the Affidavit of Loss TCT T-33454 and that the
executed by the Petitioner Petitioner executed an
covering TCT T-33454 on 7 affidavit of loss covering
February 2018 and the same TCT.
notarized as Doc. No. 162,
Page No. 33, and Book No.
XXVI, Series of 2018,
consisting of 2 pages.

I-1 Rubber Stamp Mark placed To prove that the

by the receiving officer of Petitioner caused the
the Registry of Deeds annotation of the Affidavit
Laoag City bearing Control of Loss at the Electronic
No. 2018000151, dated 7 Copy of TCT 33454.
February 2018, received at
1:37 PM and signed by the
receiving office, on the 1st
page.

I-3 Signature and the printed To prove that the

name of the Petitioner on petitioner signed the
the 2nd page. Affidavit of Loss covering
TCT – 33457.

I-4 Rubber Stamp Mark To prove that the Affidavit

certifying that the Affidavit
of Loss has been duly
registered in the Laoag City
Registry of Deeds, bearing
the signature of ATTY.
of Loss covering TCT –
33454 has been duly
registered in the Register
of Deeds, Laoag City.
 AUGUSTUS A. LUCAS on
the 2nd page.

Exhibits A-H and all of their sub-markings are attached to the

records of this case.

WHEREFORE, premises considered, it is most respectfully prayed

to this Honorable Court that the foregoing documentary exhibits be
admitted for all purposes for which each and all said exhibits were
being offered in proving the claims of the complainant/s, and with the
formal submission of the aforesaid exhibits coupled with the
testimonies of the witnesses who testified thereon.

Currimao, Ilocos Norte.

March 2, 2018.

(SGD)JERICK CHRISTIAN P. DAGDAGAN

Counsel for the Petitioner

PTR NO. 9560774/1-3-17/PTO I NORTE

IBP NO. 0990686 (LIFETIME)/3-14-16
ROLL NO. 64408/TIN 160-162-172
MCLE Compliance No. VI-1293
SAN SIMEON, CURRIMAO, ILOCOS NORTE

NOTICE

THE CLERK OF COURT

RTC Branch 12 Laoag City

GREETINGS:

Please submit the foregoing Formal Offer for the consideration

and approval of the Honorable Court immediately upon receipt hereof.

Copy Furnished:

NICO LUCERO
Assoc. City Prosec
 EXPLANATION

Copies of the foregoing Formal Offer are served upon the

prosecutor duly deputized Office of the Solicitor General and filed with
the Court by personal service.

(SGD)JERICK CHRISTIAN P. DAGDAGAN

Counsel for the Petitioner
PTR NO. 9560774/1-3-17/PTO I NORTE
IBP NO. 0990686 (LIFETIME)/3-14-16
ROLL NO. 64408/TIN 160-162-172
MCLE Compliance No. VI-1293
SAN SIMEON, CURRIMAO, ILOCOS NORTE