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    Motion To Amend

    Uploaded by

    Xhain Psypudin
    This document contains a motion to amend the caption of a petition filed in the Regional Trial Court of Pagadian City. [1] The petitioner had inadvertently listed an incorrect title number in the caption. [2] While the body and prayer listed the correct title number of T-28,723, the caption incorrectly listed T-23,743. [3] The motion requests to amend the caption to correctly reflect the title number being petitioned, as it was merely a typographical error and does not change the substance of the petition.

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    Motion To Amend

    Uploaded by

    Xhain Psypudin
    799 views3 pages
    This document contains a motion to amend the caption of a petition filed in the Regional Trial Court of Pagadian City. [1] The petitioner had inadvertently listed an incorrect title number in the caption. [2] While the body and prayer listed the correct title number of T-28,723, the caption incorrectly listed T-23,743. [3] The motion requests to amend the caption to correctly reflect the title number being petitioned, as it was merely a typographical error and does not change the substance of the petition.

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    sample motion to amend petition for reissuannce of lost title

    Original Title

    motion to amend

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    This document contains a motion to amend the caption of a petition filed in the Regional Trial Court of Pagadian City. [1] The petitioner had inadvertently listed an incorrect title number in the caption. [2] While the body and prayer listed the correct title number of T-28,723, the caption incorrectly listed T-23,743. [3] The motion requests to amend the caption to correctly reflect the title number being petitioned, as it was merely a typographical error and does not change the substance of the petition.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    799 views3 pages

    Motion To Amend

    Uploaded by

    Xhain Psypudin
    This document contains a motion to amend the caption of a petition filed in the Regional Trial Court of Pagadian City. [1] The petitioner had inadvertently listed an incorrect title number in the caption. [2] While the body and prayer listed the correct title number of T-28,723, the caption incorrectly listed T-23,743. [3] The motion requests to amend the caption to correctly reflect the title number being petitioned, as it was merely a typographical error and does not change the substance of the petition.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 3

    REPUBLIC OF THE PHILIPPINES

    NINTH JUDICIAL REGION


    REGIONAL TRIAL COURT
    Branch 19
    Pagadian City
    -o0o-

    RE: IN THE MATTER OF THE


    REISSUANCE OF THE NEW
    OWNER’S DUPLICATE COPY
    OF TRANSFER CERTIFICATE LRC CASE NO. 773-2K19
    OF TITLE NO. T-28,743 (T-
    23743) OF THE REGISTRY OF
    DEEDS OF PAGADIAN CITY,

    ELIZABETH R. GALLEGO,
    Represented by:
    MANUEL IAN R. DALAG,
    Petitioner,
    -vs-

    REGISTER OF DEEDS OF
    PAGADIAN CITY,
    Respondent.
    x----------------------------------------------x

    MOTION TO AMEND
    THE CAPTION OF THE PETITION

    Petitioner, through undersigned counsel, unto the Honorable


    Court most respectfully state and avers: THAT-

    1. Petitioner filed the petition on October 10, 2019 praying for


    the reissuance of new Owner’s Duplicate Copy of Transfer
    Certificate of Title No. T-28,723.

    2. Inadvertently, undersigned counsel typographically written


    in the caption of the case the Transfer Certificate of Title
    subject of this Petition as TRANSFER CERTIFICATE OF
    TITLE NO. T-23,743 instead of Transfer Certificate of Title
    No. T-28,723;
    3. In the body of the Petition as well as in the Prayer what is
    being prayed to be re-issued by Petitioner is the Owner’s
    Duplicate Copy of Transfer Certificate of Title No, T-28,723.

    4. The typographical error appearing in the caption of the


    instant Petition is not substantial in nature considering that
    other than the caption of the instant Petition, the Transfer
    Certificate referred to by the Petitioner, especially in its
    prayer, is TCT No. T-28, 723. In fact, copy of the Certified
    Electronic Copy of TCT No. T-28, 723 registered under the
    name of the Petitioner which was issued by the Registry of
    Deeds of Pagadian City is the one attached and made part of
    the instant Petition.

    5. It is humbly submitted that the amendment to the Petition is


    merely formal which must be made to avoid confusion.

    6. Attached hereto is a copy of the amended Petition.

    7. This motion is not intended to delay the proceedings of this


    instant Petition but solely due to the foregoing reasons.

    PRAYER

    Premises considered, it is most respectfully prayed that the


    Petition be amended and that the attached amended Petition be
    admitted.

    Other just and equitable reliefs are likewise prayed for.

    Respectfully submitted this 22nd day of January 2020, in


    Pagadian City, Philippines.

    SHINE NOVEL L. SAIPUDIN


    Counsel for Petitioner
    Roll Of Attorney No. 66798
    PTR No. 3203959 1-2-20
    IBP No. UPDATED YEAR 2020
    MCLE VI Compliance No. 0012279/valid until 4/14/22
    0560 Datoc cor Sanson St., Gatas District, Pagadian City
    NOTICES

    Branch Clerk of Court


    Branch 19, RTC
    Pagadian City
    Greetings! Please submit the foregoing motion on 24 January
    2020 to the Honorable Court, for hearing, for the Court’s kind
    consideration and approval. Thank you.

    SHINE NOVEL L. SAIPUDIN

    Copy Furnished:

    Registry of Deeds of Pagadian City ________________


    Pagadian City

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