Republic of the Philippines REGIONAL TRIAL COURT FIRST JUDICIAL REGION BRANCH ______ Baguio City


LRC CASE No. ________

With all due respect to the Honorable Court. undersigned counsel most respectfully state that: 1. Petitioners are both of legal age, Filipinos, and residents of No. 14 Tacay Road, Pinsao Proper, Baguio City, Philippines. They can be served with notices, orders, judgment writs and other court processes of the Honorable Court through the undersigned counsel whose address is indicated herein. 2. Respondent LYNNIE ANTHONETTE G. VINO, is of legal age, married, Filipino citizen, and with postal address at Lot 9 Block 1 Eagle Crest Subdivision, Bakakeng, Baguio City, Philippines and she may be served with summons and other court processes at the given address; 3. Respondents spouses EDWIN G. VALENCIA and NANCY A. Petitioners through the

VALENCIA, both of legal age, Filipino citizens, and with postal address at No. 40 Upper Malvar Street, Aurora Hill, Baguio City, Philippines, where they may be served summons and other court processes of the Honorable court; 4. The office of the Register of Deeds of Baguio City is impleaded as a necessary party, with official address at the City Hall, Baguio City where it may be served with summons and other court processes of the Honorable court;

018-2010002760 to the Registry of Deeds of . “J”. SITUATED ON THE BARRIO OF RES. 2011. 10..63 M. ALONG LINE 3 TO 4 BY PROPERTY OF GEROLD LINO PISTOLA. Banaña on April 2. SEC. CITY OF BAGUIO. 12. 6. which is. M.. 70 DEG. AT POINTS 1 TO 2 BY LOT 2-A OF THE SUBDIVISION PLAN.. 018-2010002760. CONTAINING AN AREA OF THREE HUNDRED SIXTY FOUR SQUARE METERS (364) SQ. Petitioners are the true and registered owners of a certain parcel of land which is covered by Transfer Certificate of Title with number 018-2011001191 and more particularly described as follows: Transfer Certificate of Title No.. 018-2011001191 “A PARCEL OF LAND (LOT 2-B OF THE SUBDIVISION PLAN (LRA) PSD-420673 APPROVED AS A NON-SUBDIVISION PROJECT. BEING A PORTION OF LOT 2. THENCE x x x. MORE OR LESS. (LRC) PCS-2636 CIVIL RESERVATION 211. BEGINNING AT A POINT MARKED “1” ON PLAN. AT POINTS 2 TO 3 BY (LRC) PCS-2636. STA. Before and during thePetitioners bought the subject property from Tito J. The subject property was acquired by Petitioners from Tito J.). Rimando through his attorney-in-fact Richard Banana. Rimando through the latter’s Attorney-in-Fact. “BOYD” BAGUIO TOWNSITE. BEING N. 1928. When petitioners bought the property on April 2. Richard F. Previous to the parties sale on April 2. AT POINTS 4 TO 1 BY LOT-B-4-C. a portion of a parcel of land owned by Tito J. 2011 as evidenced by a “Deed of Sale of a Portion of Registered Land” executed by the latter in Petitioners’ favor. they checked the file copy of the TCT No. 8. BOUNDED ON THE NE. 32’ W. 2011. A photocopy of the Transfer Certificate of Title of the aforedescribed parcel of land is hereto attached as ANNEX “A” and is made an integral part hereof. ON THE SW. A photocopy of the aforementioned “Deed of Sale” is hereto attached as ANNEX “B” and is made an integral part hereof. Petitioners verified with the Registry of Deeds for Baguio City the status of the 11. ISLAND OF LUZON.Petition Page 2 of 5 ‫ﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫ∞ﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫ‬ 5. FROM TRI. Rimando which was covered by Transfer Certificate of Title No. (LRC) PSD-24699. x x x. ON THE NW.. 9. The property acquired by Petitioners 7. ON THE SE.

there were no annotations of any encumbrance of adverse claims from the respondents. SERIES OF 2011 OF NOTARY PUBLIC OF BAGUIO CITY. 018-2011001191 are the following entries. 462. VALENCIA. VINO. 15. 2011001305. CLAIMING AMNG OTHERS AFFECTING THE PROPERTY DESCRIBED HEREIN IN ACCRDANCE WITH DOC. BOOK NO. MR. 14. VALENCIA AND NANCY A. NO. Petitioners had found out of these adverse claims by respondents only when the new Transfer Certificate of Title in their name was issued by the Registry of Deeds of Baguio. PAGE NO. 2011. 13. EDWIN U.“NOTICE OF ADVERSE CLAIM : EXECUTED BY LYNNIE ANTHONETTE G. Entry No. Entry No. and even when petitioners caused the annotation of Certificate Authorizing Registration issued by the BIR. CAJUCOM. PAGE NO. 2011 B. REYNALDO B. 93. to wit: A. SERIES OF 2011 OF NOTARY PUBLIC OF BAGUIO CITY. That annotated on said Transfer Certificate of Title No. BOOK NO XXXIV.” .:2011001622.“ NOTICE OF ADVERESE CLAIM : EXECUTED BY SPOUSES EDWIN G. 61. IN ACCORDANCE WITH DOC. 13. DATED MAY 12. CLAIMING AMONG OTHERS AFFECTING THE 364 QUARE METERS PORTION OF THE PROPERTY DESCRIBED HEREIN. II. NO. 2011. on April 08.Petition Page 3 of 5 ‫ﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫ∞ﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫ‬ Baguio City and found no adverse claims from respondents. MARQUEZ. DATED APRIL 15. ATTY.

2008. 48664. 17. Isabela ..00 as attorneys fees and cost for this suit. 2171442. pursuant to law. these unnecessary encumbrances of adverse claims were annotated now for more than thirty(30) days from its entry.Petition Page 4 of 5 ‫ﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫ∞ﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫ‬ 16.2008. Philippines.07. That by reason of the actuations of the respondent petitioner was compelled to secure the services of counsel and initiate the present suit and spend for this case in the amount of 15.000. Cooperative St. an order be entered directing the Register of Deeds of Baguio City to cancel Entry no. As such it is imperative that the adverse claims be cancelled. NAVARRO Of Counsel Roll No. The annotation of adverse claims on the title is an unnecessary encumbrance which is derogatory to the title and ownership of the petitioner.000. _______________ and to order the respondent ___________________ to pay 15. ___ day of July 2011. 18. BBCCC Bldg. Such other relief’s which may be just and equitable under the premises are likewise prayed for. and in view of the fact that the adverse claim has lost its effectively it is respectfully prayed that after due proceedings.. 01. May 3. By: MANAOIS AND NAVARRO LAW OFFICES Counsel for the Petitioner nd 2 Flr. 2004 PTR No. Baguio City MARK NOEL A. Baguio City. Moreover. Baguio City IBP Member 695289. PRAYER WHEREFORE.10.00 pesos. ___________ as annotated on Transfer Certificate of Title No. 01. corner Assumption Road. and it likewise imperative that the adverse claims be cancelled.

Pasig City . of Compliance No.2008. II-0011269. 08.21.Petition Page 5 of 5 ‫ﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫ∞ﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫﻫ‬ MCLE Cert.

Sign up to vote on this title
UsefulNot useful