Petition For Judicial Titling - Dela Cruz

Republic of the Philippines
Fourth Judicial Region

REGIONAL TRIAL COURT
Branch __
_______, Laguna
INRE: APPLICATION FOR

ORIGINAL REGISTRATION OF
TITLE PURSUANT TO THE
PROVISIONS OF THE PROPERTY
REGISTRATION DECREE
(PD 1529)
LRC Case No. ___________
JUAN DELA CRUZ,

Petioners,
- Versus -
REGISTER OF DEEDS OF MANILA
Respondent.
x---------------------------------------------------------x
PETITION
PETITIONERS through counsel, respectfully avers:
1. Petitioner JUAN DELA CRUZ is married to both are Filipinos,

of legal age and residing at No. 33 8th UPS San Isidro, Parañaque City while.
petitioners may be served with summons and other processes of this
Honorable Court at their respective given addresses.
2. Petitioner acquired the aforementioned parcel of land by

purchase from its previous owner PEDRO JOSE, as evidenced by a Deed of
Conveyance dated May 1, 1924 executed by the parties. A copy of which is
hereto attached as Annex “B”.
3. As shown in aforementioned Tax Declaration, petitioners

declared subject parcel of land for taxation purposes and was assessed in
their names at paid the corresponding real property taxes. Attached herewith
is a Certification dated May 1, 2013 issued by the City Treasurer attested
that petitioners are up to date in pay their property taxes including the
current year, hereto attached as Annex “C”.
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4. Petitioner predecessor in interest to determine the exact meters
and bounds of the property engaged that services of Geodetic Engineer A.
Cruz, who conducted that original survey from April 1 and worked out for
the approval of the said plan on April 1, 1930.
5. The boundaries of said parcel of land are shown in the approved

plan and accompanying certified technical description of said parcel of land
area follows:
Copy of each of the approved plan PSU-1323232 and approved

technical description are hereto attached as Annexes “D” and “E”,
respectively.
6. The aforesaid parcel of land has been surveyed in accordance

with existing laws and the implementing rules and regulations or the
Department of Environment and Natural Resources as 23423423 by
Certification lieu of the Geodetic Certificate. Copy of the Certification in
lieu of Geodetic Engineer’s Certificate for Registration Purposes dated April
1, 2016 issued by Chief Regional Survey Division is hereto attached as
Annex “F”.
7. To the best of petitioners’ knowledge and belief, there is no

mortgage or encumbrances of any kind whatsoever attesting said property
nor any other person having any estate of interest therein, legal or equitable,
in possession, remainder, reversion or expectancy;
8. Petitioners and their predecessors-in-interest have been in open,

actual continuous, uninterrupted and adverse possession in the concept of
owners of the subject parcel of land for a period of more that fifty (50) years
to date:
9. Records of the Land Management Service, Department of

Environment and Natural Resources show that no public land and
application or patent had been issued or pending before the said office
furthermore the above mentioned parcel of land is alienable and disposable,
not reserved for public use not found to be within any of the military
reservation of the government.
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10. Petitioners are in and possession and occupation of the property
and they along with their predecessors-in-interest have never been disturbed
in their possession by anyone since the time of its as acquisition by, them up
to the present time.
11. Also attached as Annex ‘G” is a Certification from the

Secretary of the Department of Environment and Natural Resources stating
that subject property is alienable and disposable.
12. The full names and addresses as far as known to the petitioners
of the owners of all adorning the property herein applied for are the
following,
13. As a consequence, thereof, petitioners are filing the present

Application for Original Registration of Title Pursuant to the Provisions of
the property Registration Decree (PD No. 1529) with the additional
requirement of the Certification from the Secretary of DENR.
PRAYER
WHEREFORE, it is respectfully prayed of this Honorable Court that

after publication, due notice and hearing a judgment be rendered.
1. Ordering that the above-described parcel of land brought and

under the operations of the Property Registration Decree. (PD 1529)
2. Ordering the Administrator of the Land Registration Authority

to issue a decree and the corresponding original certificate of title favor of
the above-named petitioners.
3. Ordering the Register of Deeds for ManilaCity to register and

confirm title in the name of the petitioners.
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Petitioners further pray for such other relief and remedies deemed just
and equitable in premises.
Manila for San Pedro City, Laguna, November 25, 2019.
BY:
ATTY PROCOPIO SAN JOSE
VERIFICATION AND CERTIFICATION OF

NON-FORUM SHOPPING
Petitioner JUAN DELA CRUZ AND JUANA DELA CRUZ are
of legal age, Filipino, both married, after having been duly sworn in
accordance with law, depose and state that:
1. We are the petitioner in the above-stated case;
2. We caused the preparation of the foregoing petition for
judicial Titling;
3. We have read the contents thereof and the facts stated therein
are true and correct of my personal knowledge and/or on the basis of
copies of documents and records in my possession;
4. We have not commenced any other action or proceeding
involving the same issues in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;
5. We the best of our knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals,
or any other tribunal or agency;
6. If we should thereafter learn that a similar action or
proceeding has been filed or is pending before the Supreme Court,
the Court of Appeals, or any other tribunal or agency, we undertake
to report that fact within five (5) days therefrom to this Honorable
Court.
JUAN JUANA
AFFIANT AFFIANT
SUBSCRIBED AND SWORN to before me this ___ day of

__________ 20189 at ____________ affiant exhibiting to me their:
VALID I.D I.D. No.
Doc. No. ;
Page No. ;
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Book No. ;
Series of 2018.
COPY FURNISHED:
REGISTRY OF DEEDS MANILA
Manila City Hall
OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo St., Legaspi Village
Makati City
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Republic of the Philippines

Fourth Judicial Region

INRE: APPLICATION FOR

JUAN DELA CRUZ,

REGISTER OF DEEDS OF MANILA

1. Petitioner JUAN DELA CRUZ is married to both are Filipinos,

2. Petitioner acquired the aforementioned parcel of land by

3. As shown in aforementioned Tax Declaration, petitioners

5. The boundaries of said parcel of land are shown in the approved

Copy of each of the approved plan PSU-1323232 and approved

6. The aforesaid parcel of land has been surveyed in accordance

7. To the best of petitioners’ knowledge and belief, there is no

8. Petitioners and their predecessors-in-interest have been in open,

9. Records of the Land Management Service, Department of

11. Also attached as Annex ‘G” is a Certification from the

13. As a consequence, thereof, petitioners are filing the present

WHEREFORE, it is respectfully prayed of this Honorable Court that

1. Ordering that the above-described parcel of land brought and

2. Ordering the Administrator of the Land Registration Authority

3. Ordering the Register of Deeds for ManilaCity to register and

Manila for San Pedro City, Laguna, November 25, 2019.

VERIFICATION AND CERTIFICATION OF

SUBSCRIBED AND SWORN to before me this ___ day of

OFFICE OF THE SOLICITOR GENERAL

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