Republic of the Philippines
8th Judicial Region
REGIONAL TRIAL COURT
Branch 28
Catbalogan City
IN RE: PETITION FOR ISSUANCE
OF NEW OWNER’S DUPLICATE
COPY OF TRANSFER CERTIFICATE
OF TITLE NO. T-1146 IN LIEU OF THE
ONE LOST.
SPCL PROC. NO. 8801-722-
2021
PEPITO P. LABENDIA for and in
Behalf of ALEJANDRO P.
LABENDIA
Petitioner.
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FORMAL OFFER OF DOCUMENTARY EXHIBITS
COMES NOW, petitioner, by counsel, unto the Honorable
Court, most respectfully offers the following documentary exhibits for
admission, to wit;
EXHIBIT“A” – Petition dated 02 July 2021 signed by Pepito P.
Labendia, petitioner consisting of five (5) pages;
Exhibit “A-1” – second (2nd) page;
Exhibit “A-2” – third (3rd) page;
Exhibit “A-3” - fourth (4th) page;
Exhibit “A-4” – Verification and Certification against forum
shopping;
Exhibit “A-4-a” - signature of Pepito P. Labendia;
Exhibit “A-4-b” - jurat and signature of the notary public;
Exhibit “A-4-c” - the receipt of a copy of the petition by
the Office of the Register of Deeds of
Samar,
Purpose: This exhibit and its series is being offered to show that
petitioner filed the instant petition in order that a new owner’s duplicate
copy of Petition for Issuance of Original Owner’s Copy of Certificate
of Title No. T-1146 be issued in lieu of the lost original duplicate copy
of the same and to prove that a copy of the petition was furnished to the
respondent Register of Deeds of Samar represented by its Acting
Register of Deeds;
EXHIBIT “B” – E-Copy of the Transfer Certificate of Title No.
T-1146, consisting of five (5) pages;
Exhibit “B-1” - Second (2nd) page;
Exhibit “B-2” – Third (3rd) page;
Exhibit “B-3” - Fourth (4th) page;
Exhibit “B-4” - Fifth (5th) page; Affidavit of Loss Entry No.
2020000621, dated 02 December 2020;
Purpose: This exhibit and its series are being offered to show that
the property covered by TCT No. T-1146 was registered in the name of
the late Victoriano Sallinas, married to the equally late Francisca
Brazas, and that the original copy thereof is still intact and existing in
the Office of the Register of Deeds of Samar;
EXHIBIT “C” - DEED OF ABSOLUTE SALE dated January
1990;
EXHIBIT “C-1” - Acknowledgment, dated January 1990;
EXHIBIT “C-1-a” - Jurat including signature of notary public;
Purpose: This exhibit and its series are being offered to show
that the vendee-brother Alejandro P. Labendia of the herein petitioner
purchased an agricultural land located at Brgy. Brgy. Camarubo-an,
Jiabong, Samar covered and embraced by Transfer Certificate of Title
No. T-1146 from the late Victoriano Sallinas, married to the equally
late Francisca Brazas;
EXHIBIT “D” - Special Power of Attorney of ALEJANDRO P.
LABENDJIA dated 02 December 2020 consisting of two (2) pages;
Exhibit “D-1” - signature of the principal, ALEJANDRO P.
LABENDJIA;
Exhibit “D-2” - jurat and signature of the notary public;
Purpose: This exhibit and its series is being offered to show that
the petitioner Pepito B. Labendia is the legal representative of his
brother vendee-brother Alenjandro P. Labendia;
EXHIBIT “E” – Affidavit of Loss of Ownership’s Duplicate
Copies of Land Title, dated 01 December 2020;
Exhibit “E-1” - signature of Pepito P. Labendia ;
Exhibit “E-1-a” - jurat including signature of notary public;
Purpose: This exhibit and its series is being offered to prove
that the original owner’s duplicate copy of TCT No. T-1146 lost and
that petitioner, Pepito P. Labendia executed an affidavit of loss
alleging, among others, the circumstances leading to the loss of the
owner’s duplicate copy of TCT No. T-1146 and this affidavit was filed
with the Office of the Register of Deeds of Samar;
EXHIBIT “F” - Order of the Honorable Court, dated 25 August
2021;
Purpose: This exhibit is being offered to show that the
Honorable Court issued an Order dated 25 August 2021 finding the
petition to be sufficient in form and substance and ordering the
petition to be posted in the bulletin board of Branch 28, Regional Trial
Court, Catbalogan City, Municipal Hall of Jiabong, Samar, and at
Brgy. Hall of Brgy. Camarubo-an, Jiabong, Samar where the property
is located;
EXHIBIT “G” - Certificate of Posting, dated 10 September 2021;
Purpose: This exhibit is being offered to prove that in
compliance with the Order of the Honorable Court dated 25 August
2021, posted the Order at the bulletin board of Branch 28, Regional
Trial Court, Catbalogan City, Municipal Hall of Jiabong, Samar, and
at Brgy. Hall of Brgy. Camarubo-an, Jiabong, Samar where the
property is located;
.
WHEREFORE, it is most respectfully prayed, that the
documentary exhibits being offered for admission be ADMITTED and
thereafter the petitioner rests his case.
Catbalogan City, Samar, 11 January 2022.
DEMETRIO MEDINO J. ACUBA
Counsel for the Petitioner
G/F Laohoo Bldg., 196 San Bartolome St.
Brgy. 03 6700 Catbalogan City
IBP Official Receipt Nos. 15865. 158656
PTR. No. 8318620 Catbalogan City 1.4.21
Roll of Attorneys No. 71321
MCLE Compliance No. VI-0030149
The Branch Clerk of Court
Regional Trial Court
Bulwagan ng Katarungan
Catbalogan City
Madam/Sir:
Please submit the foregoing Formal Offer of Documentary
Exhibits for the kind consideration and resolution of the Honorable
Court immediately upon receipt hereof.
ATTY. DEMETRIO MEDINO J. ACUBA
Copy Furnished: (Personal Service)
Office of the Register of Deeds of Samar
Catbalogan City
