Republic of the Philippines

Regional Trial Court of Zamboanga del Norte

Ninth Judicial Region
Branch 28
Liloy, Zamboanga del Norte

IN RE: PETITION FOR ISSUANCE OF MISC. PROC. NO.________

NEW TRANSFER CERTIFICATE
OF TITLE IN LIEU OF THE LOST
CERTIFICATE OF TITLE NO. T-86398

JERRY ABALLE BALMADRES

Petitioner,

Represented by his
Attorney-in-Fact
JESUS TAN SR.
X---------------------------------------------------------/

PETITION

COMES NOW, the petitioner, represented by his Attorney-In-

Fact JESUS TAN SR, to this Honorable Court, most respectfully
states and alleges:

1. That the petitioner, JERRY ABALLE BALMADRES, is of

legal age, Filipino Citizen, single and a resident of Santa
Cruz, Liloy, Zamboanga del Norte, and is hereby represented
in this instant petition by his Attorney-In-Fact JESUS TAN
SR, who is likewise of legal age, Filipino citizen, widower, and
a resident of Dapaon, Sindangan, Zamboanga del Norte
where he may be served upon with any processes of this
Honorable Court. The representation is pursuant to a Special
Power of Attorney executed by the herein petitioner JERRY
ABALLE BALMADRES before the faith of Notary Public
ALFRED S. CASIPONG, known as Doc. No. 5235; Page
No.52; Book No. XIX; Series of 2017, hereto attached as
Annex “A”;

2. That the petitioner is the lawful owner of parcel of land

covered by Transfer Certificate of Title No. T-86398, which is
more particularly described as follows:

“A parcel of land (Lot G-9-B) of the subdivision plan, PSD-09-

069758, being a portion of G-9, PSD-09-065358, situated in
the Barangay of Liloy, Municipality of Sindangan, Province of
Zamboanga del Norte, Island of Mindanao. Bounded on the
SE along line 10-11 by Municipal Road along lines 11-13-1
 by Lot G-9-A, all of the subdivision plan along line 1-2 by
Municipal Road, along line 2-3 by Lot F, (LRC) PSD-83380,
on the SW along lines 3-5 by Lot G-B, PSD-09-065358 along
line 5-6 by Road Lot G-1, Psd-09-065358, along line 7 by Lot
G-3, Psd-09-065358, along line 7-8 by Lot G-2, Psd-09-
065358, along line 8-9 by Lot E, (LRC) Psd-83380; and on
the NW along line 9-10 by Maximo Bandico, Lot 3072, Pls-6,
containing an area of “THIRTEEN THOUSAND TWENTY
TWO (13,022) SQUARE METERS.”

3. That under the present provincial geographical set-up, the

said parcel of land above-described is situated in the
Municipality of Liloy, Zamboanga del Norte and, thus, within
the territorial jurisdiction of this Honorable Court;

4. That the above-described property is registered under the

name of the herein petitioner and he was duly issued a
Duplicate Owner’s Copy of the said Transfer Certificate of
Title No. T-86398;

5. The petitioner kept the title of the said parcel of land at his
home in drawer where he mostly kept his legal documents;

6. When petitioner tried to search for the said Transfer

Certificate of Title, he could no longer retrieve the same from
the place where he usually kept it

7. Despite his earnest efforts to locate the said Transfer

Certificate of Title No. T-86398, the same could no longer be
found, and thus, he considered it lost for all legal intents and
purposes;

8. That consequent thereof, petitioner executed an Affidavit of

Loss pertaining to the loss of the owner’s copy of Transfer
Certificate of Title No. T-86398, before the faith of Notary
Public Alfred S. Casipong known as Doc. No. 5236; Page No.
53, Book No. XIX, Series of 2017; hereto attached as Annex
“B”;

9. That, thereafter, petitioner had caused the aforesaid Affidavit

of Loss to be registered with the Register of Deeds of the
Province of Zamboanga del Norte, and had it annotated on
the original copy of the Transfer Certificate of Title No. T-
86398, a copy of which is hereto attached as Annex “C”;

10. That the annotation of the Affidavit of Loss at the

Memorandum of Encumbrances in the Transfer Certificate of
Title No. T-86398 is marked as Annex “C-4”;
 11. That pursuant thereto, petitioner was issued true electronic
copy of the above-mentioned Transfer Certificate of Title
attached as Annex “C”;

12. That the herein petitioner hereby assures that the parcel of
land covered by the Transfer Certificate of Title No. T-86398
subject matter of the instant petition, is free from any lien and
encumbrance, and should this petition be approved, the same
will not prejudice any third person.

P R A Y E R

WHEREFORE, in the light of all the foregoing, it is most

respectfully prayed of this Honorable Court that new owner’s duplicate
copy of Transfer Certificate of Title No. T-86398, with the same force
and effect as the lost title, be issued in favor of JERRY A.
BALMADRES, the herein petitioner.

Other reliefs consistent with law, justice and equity are likewise
prayed for.

Respectfully submitted this _______________ in Liloy,

Zamboanga del Norte, Philippines.

JESUS TAN SR.

Attorney-in-fact-

Subscribed and sworn to before me this _________ day of

April, 2018, in Poblacion, Sindangan, Zamboanga del Norte, affiant
personally came and showed to me his competent evidence of
identity, details of which are written below his name, and personally
signed the foregoing document in my presence and avowed under
penalty of law to the whole truth of the contents of said instrument..
WITNESS MY HAND AND SEAL.

Copy furnished by substituted service:

The Register of Deeds

Province of Zamboanga del Norte
Capitol Building, Dipolog City
Republic of the Philippines )
PROVINCE OF ZAMBOANGA DEL NORTE )S.S.
Municipality of Sindangan )
x---------------------------------/

VERIFICATION AND CERTIFICATION

ON NON-FORUM SHOPPING

I, JESUS TAN SR., of legal age, Filipino, widower, and a resident of

Ramon Magsaysay, Sindangan, Zamboanga del Norte, under penalty of
perjury hereby declare under oath:

1. That I am the Attorney-In-Fact of JERRY A. BALMADRES who

stands petitioner of this instant petition;

2. That in such capacity, I have caused the preparation and filing of

this PETITION;

3. That I have supplied all the allegations contained therein and the
same are true and correct to the best of my own personal knowledge and
based on authentic documents;

4. That I hereby certify under oath that I have not commenced any
other action or proceeding involving the same issue in the Supreme Court,
Court of Appeals or any other tribunal or agency; That to the best of my own
personal knowledge, no such action or proceeding is pending in the
Supreme Court, Court of Appeals or any tribunal or agency; and that if I
should thereafter learn that a similar action or proceeding has been filed or
is pending before the Supreme Court, Court of Appeals or any other tribunal
or agency, I undertake to report the fact within five (5) days therefrom to this
Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

___________ at Sindangan, Zamboanga del Norte, Philippines.

JESUS TAN SR.

Affiant

SUBSCRIBED AND SWORN to me, in abovementioned date and

place, affiant personally came and personally known to me as the same
person who signed the foregoing instrument before me and avowed under
penalty of law to the whole truth of the contents of said instrument.
WITNESS MY HAND AND SEAL the date and place above-written.

Doc. No. ______;

Page No. ______;
Book No. _____;
Series of 2018