Republic of the Philippines

Fourth Judicial Region

REGIONAL TRIAL COURT
Branch __, Quezon City

IN RE: PETITION FOR THE

ISSUANCE OF A NEW
OWNERS COPY OF LRC Case No. ________
CERTIFICATE OF TITLE NO.
28304 OF THE REGISTRY OF
DEEDS OF QUEZON CITY

JESUS M. CATACUTAN and

VIOLETA V. CATACUTAN
Petitioners,

-versus-

REGISTRY OF DEEDS OF
QUEZON CITY
Respondent.
x---------------------------------------------x

PETITION

PETITIONERS, JESUS M. CATACUTAN and VIOLETA V.

CATACUTAN, through the undersigned counsel and unto this
Honorable Court, most respectfully state: That

1. The petitioners are both of legal age, Filipino citizens and

both with residential and postal address at Lot 625 N Pluto St., Brgy.
Bahay Toro, Quezon City. Petitioners can be served with summons and
other processes of this Honorable Court through the undersigned
counsel Alferos, Armas and Associates Law Office with address Unit K,
No. 1143 San Francisco Del Monte Avenue, Brgy. Paltok, Quezon City.

2. The petitioners are the buyers of a parcel of land, by virtue

of a Deed of Absolute Sale, comprising an area of FIVE HUNDRED
AND EIGHTY SQUARE METERS (580 m2), more or less, situated in
Lot 625 N Pluto St., Brgy. Bahay Toro, Quezon City and more
particularly described as follows:

A parcel of land (Lot 625-P of the subdivision

plan Psd-34680, being a portion of Lot 625 of the
Piedad Estate, GLRO Record NO. 5975, situated
in Quezon City. Bounded in the N., by Lot 625-N
of the subdivision plan; on the NE., by Lot 624 of
 Piedad Estate; and Lot 625-N of the subdivision
plan; on the SE., by Lot 625-O of the subdivision
plan; and on the SW., by Lot 625-O of the
subdivision plan and Road. Beginning at a point
marked 1 on plan, being S. 6 deg. 21E., 297.44
m. from L. Mon. 9, Piedad Estate, thence S. 25
deg. 02E., 11.58 m to point NE; thence N. 75 deg.
12W., 4.54 m. to point NE; thence N. 75 deg.
12W., 4.54 m. to point 3; thence N. 24 deg. 7W.,
9.37 m. to point 4; thence S. 71 deg. 34W., 13.19
m. to point 5; thence S. 75 deg. 12W., 28.96 m.
to point 6; thence S. 75 deg. 7W., 17.70 m. to
point 7; thence S. 87 deg. 00N., 31.00 m. to
point 8; thence S. 74 deg. 34E., 16.46 m. to point
9; thence S. 60 deg. 11W., 3.5 m. to point 10;
thence S. 54 deg. 30E., 15.80 m. to point 11;
thence S. 66 deg. 54E., 2.20 m. to point 12;
thence S. 74 deg. ___., 4.00 m. to point of
beginning; containing an area of FIVE
HUNDRED EIGHTY (580) SQUARE METERS,
more or less. All points referred to indicated on
the plan and are marked on the ground as follows:
point 6 and 11 by old P.L.S. Conc. Mons.; and
the rest by P.L.S. Cyl. Conc. Mons.; bearing true;
Entry No. declination 0 deg. 48E., date of the
original survey, July on January 29, 1952;

A copy of the Deed of Absolute Sale is hereto attached and marked

as Annex A;

3. The above-mentioned land was duly registered and owned by

Spouses GRACIANA C. MENDOZA and PEDRO C. MENDOZA, the
vendors, under Transfer Certificate of Title No. RT-93503;

4. The Owners Copy of Transfer Certificate of Title No. RT-

93503, including all necessary documents relative to the purchase, was
turned-over to the Petitioners;

5. The above-mentioned owners copy was lost and an Affidavit

of Loss was executed by herein Petitioners which they submitted and
registered with the Registry of Deeds of Quezon City. True Electronic copy
of the document on file with the Registry of Deeds of Quezon City of the
Transfer Certificate of Title No. RT-93503 with the annotation of the
Affidavit of Loss is hereto attached as Annex B toB-1, respectively;

6. No other deed or instrument is known affecting the subject

property has been presented for registration in the Office of the Registry
of Deeds of Quezon City and the adverse claim against the same is
annotated by only the Petitioners themselves as shown by the Certified
True Copy of Transfer Certificate of Title No. RT-93503 issued by the
Registry of Deeds of Quezon City.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable

Court, that after hearing, judgment be rendered, ORDERING the Registry
of Deeds of Quezon City, Metro Manila to ISSUE a NEW Owners Copy of
the Transfer Certificate of Title No. RT-93503.

Other reliefs just and equitable under circumstances are likewise

prayed for.

RESPECTFULLY SUBMITTED.
10 April 2017, Quezon City

ALFEROS ARMAS & ASSOCIATES

Law Office
Unit K, No. 1143 San Francisco Del Monte Ave.,
Barangay Paltok 1105, Quezon City

By:

JOHN THOMAS S. ALFEROS III

PTR No. 2182053; 01.06.16 Q.C.
IBP No. 1018433; 01.06.16; Q.C.
Roll No. 48188; Page No. 138; Book no. XX
MCLE Compliance No. V-0019255; 04.15.16 until 04.14.19
Mobile No. 0918-9390566
jtsalferosiiilaw@yahoo.com