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LTD WRITING EXERCISE: PETITION FOR APPLICATION OF LAND REGISTRATION

KRIZEA MARIE K. DURON

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT OF NEGROS ORIENTAL
7th Judicial Region
Branch 30
Dumaguete City
IN RE: PETITION FOR THE
ORIGINAL REGISTRATION
AND/OR JUDICIAL TITLING
OF LOT Lots 4751-A (LRC)
Psd-50533 SITUATED IN
BRGY. MANIPIS, TANJAY CITY

Land Registration Case No. 2016-N-213


LRA Record No. ____

KKK CORPORATION, Duly


Represented by KRIZEA MARIE
K. DURON,
Petitioner,
X------------------------------------------/
PETITION FOR APPLICATION OF ORIGINAL REGISTRATION
The PETITIONER, by and through counsel unto this Honorable Court, most
respectfully asseverates that he applies to have the land hereinafter described be brought under
the operation of the Land Registration Act, and to have the title thereto registered in the name of
the KKK CORPORATION, and further avers that:
1.

The petitioner, KKK CORPORATION is a stock corporation, duly organized


and incorporated in accordance with the laws of the Republic of the
Philippines involved in the retail trade business;

2.

For purposes of this petition, KKK Corporation has authorized KRIZEA


MARIE K. DURON, to file this petition by virtue of a Secretarys Certificate
executed by Christal Faith Javier, Assistant Corporate Secretary; a copy of said
Secretarys Certificate is hereto attached and correspondingly marked as
ANNEX A;

3.

That the petitioner is the legitimate owner of the land, known as LOT Lots
4751-A (LRC) Psd-50533. The said land, consisting of one (1) parcel is
situated, bounded and described as shown on the plan and technical
descriptions attached hereto and made a part hereof: Beginning at a point mark
1 on the plan being S.85 deg 04W, 250.50 from Rural Bank of Tanjay,
thence N.58 deg .37 W, 7.00 m to point 2; thence N 31 deg 41 E, 35m to
point 3; containing an area of Eight hundred sixty seven (867) square meters
more or less;
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LTD WRITING EXERCISE: PETITION FOR APPLICATION OF LAND REGISTRATION


KRIZEA MARIE K. DURON

4.

The petitioner has right of ownership and possession of the above-mentioned


lot by virtue of a Memorandum of Agreement (MOA) between KKK
Corporation and GAIL BORROMEO with consideration of PHP 980,000.00,
Philippine Currency. Hereto attached and marked as ANNEX B is a copy of
said MOA forming an integral part of this petition;

5.

That petitioner and its predecessors-in-interest HAVE BEEN IN OPEN,


CONTINUOUS, EXCLUSIVE AND NOTORIOUS POSSESSION AND
OCCUPATION OF ALIENABLE AND DISPOSABLE LANDS OF THE
PUBLIC DOMAIN UNDER A BONA FIDE CLAIM OF OWNERSHIP
SINCE JUNE 12, 1945 AND IS PRESENTLY UNDER THE EXCLUSIVE
PROPERTY OF THE APPLICANT.;

6.

That said land at the last assessment for taxation was assessed at P800,000,
Philippine currency;

7.

That to the best of my/our knowledge and belief, there is no mortgage or


encumbrance of any kind whatsoever affecting said land, nor any other person
having any interest therein, legal or equitable, or in possession, other than as
follows: None;

8.

The aforesaid parcel of land as above-mentioned, situated in Brgy. Manipis,


Tanjay City is covered by Tax Declaration No. 89-10-043-00076, the latest
issue, which is attached herein and marked as ANNEX C. Said parcel of
land, based on the above-mentioned Tax Declaration is further described as
follows:
Tax Declaration No. 89-10-043-00076
Lots 4751-A (LRC) Psd-50533
A parcel of land, situated in the Barangay of Manipis, Tanjay City, Negros
Oriental Beginning at a point mark 1 on the plan being S.85 deg 04W,
250.50 from Rural Bank of Tanjay, thence N.58 deg .37 W, 7.00 m to point 2;
thence N 31 deg 41 E, 35m to point 3; containing an area of Eight hundred
sixty seven (867) square meters more or less;

9.

That the land applied for is bounded on the North by Public Land; on the West
by a road; on the South by Public Land and on the East by TCT-T-12345;

10.

A copy of the certification, to this effect issued by the OIC, Regional Technical
Director, LMS, DENR-7 is attached herein and marked as ANNEX D, A
blue print of the approved advance plan, Ap-07-00467, together with its
approved narrative technical description as attached herein and marked as
ANNEX E and ANNEX F respectively. Also, attached and marked as
ANNEX G is a copy of the certificate of Geodetic engineers certificate
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LTD WRITING EXERCISE: PETITION FOR APPLICATION OF LAND REGISTRATION


KRIZEA MARIE K. DURON

issued by the OIC, Regional Technical Director, LMS, DENR-7 and the latest
issue of Tax Declaration No. 99-20-022-00084 marked as ANNEX H.
WHEREFORE, premises considered it is most respectfully prayed that judgment be
rendered ordering that Lot Lots 4751-A (LRC) Psd-50533, Tanjay CAD 903, be brought under
the Land Registration Act and that the same be adjudged in the name of the petitioner and after
judgment shall attained finality, a decree of registration be issued in favor of the petitioner
herein.
Such other reliefs just and equitable are likewise prayed for.
November 5, 2016, Dumaguete City, Philippines.
MOST RESPECTFULLY SUBMITTED.
KRIZZA MAE L. BATULAN
2nd Floor Duron Building
EJ Blanco Drive cor. Mango Avenue, Dumaguete City
Telephone no. 422-8881
PTR. NO. 0901763-1/7/2016
IBP NO. 960-737-11/5/2013
Issued in Dumaguete City