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 Secretary’s Certificate executed by Christal Faith Javier, Assistant Corporate Secretary; a copy of said Secretary’s 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 04’W, 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; 1
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 04’W, 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 engineer’s certificate 2
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
3
