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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


11th JUDICIAL REGION
BRANCH XVI

Paul V. Cruz
Plaintiff
Civil Case No. 897267
For: Consolidation of
Ownership in Pacto
de Retro Sale
-versus-

Diego C. Santos
Defendants
x------------------x

PETITION FOR CONSOLIDATION OF OWNERSHIP IN


PACTO DE RETRO SALE
Petitioner, thru counsel, respectfully states that:
1. The Petitioner bought under the pacto de retro from the vendor Diego
C. Santos, a certain piece of real property, as evidenced by an
instrument dated September 24, 2014, a copy of which is hereto
attached and made a part of this petition as Annex “A”;
2. The date of repurchase namely September 24, 2019 having been
expired and the vendor not being able to repurchase the same under
the terms and conditions therein stated, the ownership over the said
real property has now become consolidated in the vendee petitioner;
3. For purposes of recording in the Registry of Property, the
consolidation or ownership in the vendee-petitioner, it is necessary
that a judicial order be issued to this effect, pursuant to the provision
of Art. 1607 of the New Civil Code.

WHEREFORE, after due notice to the vendor, it is respectfully prayed


that an order be issued by this Honorable Court, ordering the
consolidation of ownership on the real property therein mentioned in the
vendee-petitioner for all legal purposes.

Davao City, 12 February 2020.


(SGD.) GABRIEL S. TECSON
Counsel for Plaintiff
Puan, Davao City, Philippines
Roll No. 234545, 05/05/10
PTR No. 22334567, 2/10/20, Bajada, Davao City
IBP No. 98776, 1/04/20, Davao City Chapter
MCLE COMPLAINCE No. 887649
REPUBLIC OF THE PHILIPPINES )
CITY OF DAVAO ) S.S.

VERIFICATION AND CERTIFICATION

I, Paul V. Cruz, Filipino, of legal age residing at 143 Lily St.,


Cabantian, Davao City, after being sworn to in accordance with law, deposes
and says that:

1. I am the Petitioner in the above-entitled case;

2. The facts stated in the above petition are true and correct to the best of
my knowledge and authentic records;

3. I have not commenced any action or filed any claim involving the
same issues in any court, tribunal or quasi-judicial agency and, to the
best of my knowledge, no such other action or claim is pending in
them; and

4. If I should learn that the same or similar action or claim has been filed
or is pending after its filing, I shall report that fact within five days
from notice to the court or where the petition has been filed.

Davao City, Philippines, this 12th day of February 2020.


(SGD.) Paul V. Cruz
Affiant

SUBSCRIBED and sworn to before me, this 12th day of February


2020, in the City of Davao by Paul V. Cruz with Passport No. 2009012
issued on 17th of March 2019 at Department of Foreign Affairs – Gaisano
Mall of Tagum that he is the same person who signed the foregoing
document before me and acknowledged that she voluntarily executed the
same.
(SGD.) GRIDLIN A. MATILAC
Notary Public for Davao City
Commission Serial No. 2020-0379-2022
Doc. No. 92 Until December 31, 2021
Page No. 20 Attorney’s Roll No. 10772
Book No. I PTR No. 7862245 B; 01-02-20; Davao City
Series of 2020 IBP O.R. No. 024454; 01-02-20; Davao City
MCLE Compliance No. 003425
Notarial Commission No. 123456

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