Republic of the Philippines)

Province of Abra, Bangued ) S.S.

ADVERSE CLAIM
WE, SPOUSES PETER PAUL V. BANEZ and MA. ELENITA V.
BANEZ, both of legal age, Filipinos, and with residence at !"A Al#on
st., Pro$ect %, &ue'on (it), and after having been dul) sworn to in
accordance with law, hereb) depose and state, that*
. We are the #e#bers of the Board of +ecropolis, ,nc.
-.(orporation/), a corporation dul) organi'ed under the
laws of the Philippines.
0. 1n 02 3ece#ber 0!, the (orporation through its Board,
passed Board Resolution +o !"0! -Anne4 .(/),
authori'ing the sale of the only propert) of the (orporation
in favor of 5oreta F. 6alera, #arried to Raul A. 6alera7 that
such propert) of the corporation is #ore particularl)
described as follows*
1(8 !"%9: -now 8(8 ;"0!0!!!!:)
A parcel of land -5ot 22;, (A3 ;%: Bangued
(adastre Plan AP"%!!"!!!!%:, 5R (ase +o
+"20 5RA Record +":;2!9) together with the
i#prove#ents thereon situated at <one :,
=unicipalit) of Bangued Province of Abra,
,sland of 5u'on Bounded on the SE Points "0
b) 5ot 22% (A3 ;%: case 9 b) >ai#e Barros7
on the SW points 0"% b) Baranga) Road -!.!!
= wide) on the +W points b) %"2 b) 5ot 22%
Ale$andro Ballestra7 on the +E and +W points
b) 2":, b) 5ot 222 Efren Agcaoili7 on the +W
points :"9 b) 5ot 22: b) &uirino 6iado7 on the
+W points 9"? b) 5ot 229 b) Anita Astudillo
on the +W and +E points ?"! b) 5ot 220%
Rosa 6as@ue' on the SE +W and +E points !"
0" b) 5ot 2209 Efren Agcaoili in (A3 ;%:
case 9, Bangued (adastre beginning at a point
#arAed ./ on Plan being S 9 3eg !9BW.,
?09.0% = fro# B55= +o (ad ;%: Bangued
(adastre, thence*
S. %: 3eg ?BW 0!.?% = to Point 0
+. 9 3eg 20BW 29.0 = to Point %
+. 0; 3eg !%BE 09.2; = to Point 2
S. 9? 3eg 2?BE %C.9? = to Point ;
+. 0% 3eg 0:BE 2:.22= to Point :
+. %9 3eg !?BE 22.:0= to Point 9
+. %9 3eg 0BE C.%= to Point ?
+. %; 3eg 20BE 0.2!= to Point C
S. 9: 3eg %2BE 0?.C= to Point !
S. 9 3eg !BW !9.CC = to Point
+. ?% 3eg 00BE 9.C= to Point 0
S. ! 3eg !?BE 2;.:C = to Point of
Beginning7 containing an area of 8welve
8housand +ine Dundred Fifteen S@uare =eters
and 8hirt) 8hree S@uare 3eci#eters - 0,
C;.%%) #ore or less. All Points referred to are
indicated on the plan and are #arAed on the
ground bearing grid date of original surve)
>anuar) 09, C99. -A cop) of 1(8 !"%9: is
hereto attached as Anne4 .A/ and a cop) of
8(8 ;"0!0!!!!: is hereto attached as
Anne4 .A"/)
%. 8he said sale of the Propert) of the (orporation is null and
void for lacA of consent on the part of the (orporation and
stocAholders and lacA of consideration.
2. 8here was lacA of consent on the part of the (orporation
because the vote of the stocAholders representing #ore
than two"thirds -0E%) of the outstanding capital stocA was
not obtained7 that the votes of herein aFants, who are also
stocAholdersEdirectors of the (orporation, were not
obtained who owns at least E%G of the outstanding capital
stocA of the (orporation. -A cop) of the Articles of
,ncorporation showing the respective ownership of shares
is hereto attached as Anne4 .B/).
;. 8here was lacA of consent on the part of the stocAholders
because no written notice of special #eeting of
stocAholders was #ade for the purpose of selling the onl)
propert) of the (orporation such that the alleged sale of
the propert) of the (orporation was #ade in violation of
Section 2! of the (orporation (ode -see Anne4 .A/ hereof).
:. 8here was lacA of consideration because there was no
pa)#ent of the consideration of the purchase price.
9. As it stands right now, 1(8 !"%9: has been cancelled and
8(8 ;"0!0!!!!: issued under the na#e of 5oreta F.
6alera, #arried to Raul A. 6alera.
?. Hnless an adverse clai# is annotated on the above
#entioned parcel of land, the (orporation is in danger of
being further defrauded and deprived of its $ust and valid
right over the aforedescribed parcel of land.
C. 8his AFdavit of adverse clai# is being e4ecuted for the
infor#ation and proper guidance of all concerned, the
public at large, and for the purpose of attesting to the
truthfulness of the foregoing allegations and in support of
our re@uest for the annotation of an adverse clai# over the
afore#entioned parcel of land.
!. We are therefore e4ecuting this AFdavit for the purpose of
attesting to the truthfulness of the foregoing allegations
and in support of our re@uest for the annotation of an
adverse clai# over the parcel of land covered b) the
8ransfer (ertiIcate of 8itle +o. 8(8 ;"0!0!!!!: as the
sa#e #a) still be soldEconve)edE#ortgaged again to
so#e other parties for our protection pending an)
application for +otice of 5is Pendens in the future, as the
need arises7

PETER PAUL V. BANEZ MA. ELENITA V.
BANEZ
SHBS(R,BE3 A+3 SW1R+ 81 before #e this JJJ da) of JJJJJJ
0!% in the (it)EProvince of JJJJJJJJJJ. AFants e4hibited to #e their
JJJJJJJJJJJJJJJJJ with no. JJJJJJJJJJ and JJJJJJJJJJJJJJJJJ with no.
JJJJJJJJJJ infor#ation subscribed below their respective na#es.
W,8+ESS =K DA+3 A+3 SEA5, on the date and place Irst
above#entioned.
3oc. +o. JJJ
Page +o. JJJ
BooA +o.JJJ
Series of 0!%