COMES NOW, petitioner ________________________________ through counsel, unto this Honorable Court, respectfully alleges:
- That petitioner is of legal age, _____________ , Filipino citizen and residing at _______________; that respondent __________________________ is the Register of Deeds of _____________ where he may be served with summons and other court processes;
- That petitioner is the registered owner of a parcel of land located at _________________ and covered by Transfer Certificate of Title No. _____________, Register of Deeds of ____________, free of any encumbrances;
- That on April 5, 2013 the office of the register of Deeds of Makati City was burned and all the Torrens Titles in said office including T.C.T. No. _____________ were burned;
- That said transfer certificate of title was never mortgaged or sold to anyone.
WHEREFORE, it is respectfully prayed that the Register of Deeds of _____________ issue a reconstituted original certificate of title based on the owner’s duplicate certificate of title hereto attached in the name of herein petitioner.
Other just and equitable reliefs are likewise prayed for.
______ _____________ 20___
City of _____________ .
Counsel for the Petitioner
Original TCT was lost due to a fire which destroyed all the records in the Register of Deeds