Republic of the Philippines

REGIONAL TRIAL COURT

6TH Judicial Region
Branch ____
Iloilo City

IN RE: THE ISSUANCE OF THE

OWNERS COPY OF THE TRANSFER
CERTIFICATE OF TITLE (TCT) NO.
T-59380, TCT NO. T-59381, TCT NO.
T-59382 AND TCT NO. T-29383

ARTURO CALSAS

Petitioner,

-versus-

CAD. CASE NO. _____

PETITION

Petitioners, through the undersigned counsel most respectfully states:

1. That Petitioners ______________, ______________,

______________, ______________, ______________ and Ibrahim A.
Calanao ________________________________ where they may be served
with the processes of this Honorable Court;

2. That petitioners are now considered absolute and exclusive

owners of the following described real properties:

Lot No. Location Certificate Area

of (in sq.
Title No. meters)
2226-C-9 Balabago, Jaro, Iloilo City T-59380 389
2226-C-10 Balabago, Jaro, Iloilo City T-59381 548
2226-C-11 Balabago, Jaro, Iloilo City T-59382 366
2226-C-12 Balabago, Jaro, Iloilo City T-59383 284

All issued by the Register of Deeds of Iloilo City

Being the buyers of the same is a public auction conducted in
accordance with law evidenced by a Final Deed of Sale dated September 06,
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2007, copy of which is marked and attached hereto as Annex A to be
taken as an integral part hereof;

3. That petitioners intend to register the aforesaid Final Deed of

Sale (Annex A) with the Registry of Deeds of Iloilo City which consequently
would require the surrenderer to the said Registry of Deeds of Iloilo City of
the owners copy of the aforementioned owners duplicate certificates of title.
However, despite demand made upon the previous registered owner
International Broadcasting, Corporation, it refused and failed and still refuses
and fails to turn over to petitioners said owners duplicate copies of the
certificates of title. Copy of the letter of demand is hereto marked and
attached as Annex B to be taken as integral part hereof;

4) That under the foregoing circumstances, said copies of owners

duplicate certificates of title mentioned in paragraphs 2 hereof, can be
considered lost and/or destroyed for all intents and purposes;

5) That these are no other persons who may be or might be interested

in the aforementioned parcels of land covered by the lost and/or destroyed
owners duplicate of certificates of title made subject matters of the instant
petition;

6) That petitioners have no information of any encumbrance

whatsoever affecting the above-described parcels of land, on which has been
previously executed or is now pending registration in the Registry of Deeds
having jurisdiction over said parcels of land; and

7) That the original copies of the said certificates of title remain intact
in the file of the Registry of Deeds of Iloilo City as certified to by the said
office. Marked and attached hereto as Annex C is a copy of said
certification to be taken as an integral part hereof.

PRAYER

Wherefore, it is respectfully prayed that after due notice and hearing

judgment be rendered:

1) Declaring the Owners Duplicate Copy of Transfer Certificate of

Title Nos. T-59380, T-59381, T-59382 and T-59383 issued by the Registry
of Deeds of the City of Iloilo that have been lost as null and void; and

2) Ordering the Register of Deeds of Iloilo City to issue the Owners

Duplicate Copy of Transfer Certificate of Title Nos. T-59380, T-59381, T-
59382 and T-59383 and/or destroyed in lieu of the lost ones which were lost
and/or destroyed after payment of the corresponding legal fees.

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 Other reliefs just and equitable in the premises are likewise prayed for
Iloilo City, Philippines, ___ October 2017.

DUREMDES NAVA VILLEGAS

Counsel for Petitioner
nd
2 floor, A and L Bldg., E. Lopez St.,
Jaro, Iloilo City

VERIFICATION/CERTIFICATION
We, ANGELO B. SOLARTE, of legal age, married, Filipino and
resident of Iloilo City, Philippines, subscribing under oath, depose and state:
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 That we am the duly authorized representative and Executive Director
of Complainant Taytay sa Kauswagan, Inc.;
That we have caused the preparation and filing of the foregoing
PETITION in the perjury case docketed as NPS Docket No. VI-10-INV-
16K-00703 entitled Taytay sa Kauswagan, Inc. v. Randy P. Alojado, and
have read and understood the contents thereof;
That we have read the foregoing PETITION and all the allegations
contained therein are true and correct as of my personal knowledge and/or
based on authentic records;
That we have not theretofore commenced any other action or filed any
claim involving the same issue raised in this PETITION in any Court,
tribunals or quasi-judicial agencies, and that to the best of my knowledge,
no such action or claim is pending therein. However, should I thereafter learn
that the same or similar action or claim has been filed or is pending with any
Court, tribunal or quasi-judicial agencies; I hereby undertake to promptly
report the fact within five (5) days therefrom to the Honorable Court.

ANGELO B. SOLARTE
Affiant
TIN NO. 138-141-714

SUBSCRIBED AND SWORN to before me, this ___ day of

September 2017 at Iloilo City, Philippines, affiant exhibited to me his/her
________________________ as competent evidence of identity.

Doc No. ______;

Page No. ______;
Book No. ______;
Series of 2017.