Republic of the Philippines )

City of Dagupan ) S.S.

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AFFIDAVIT OF ADVERSE CLAIM/

PRECAUTIONARY NOTICE

I, HAGIBIS A. FAJARDO, of legal age, Filipino, and a resident of

Barangay Pogo, Mangaldan, Pangasinan, after having been duly sworn to
in accordance with law, depose and say:

That I am the actual cultivator and possessor over the parcel of land
of ANTONIO S. VERGARA, SR. of Barangay Poblacion, Mangaldan,
Pangasinan particularly described as follows:

“A parcel of land situated in Barangay Pogo, Mangaldan,

Pangasinan, covered by Tax Declaration No. 342 and with an
area of Five Thousand (5,000) square meters, more or less and
with market value of P2,360.00. Bounded on the North by
Mariano Guban; on the East by Nicolas Quinto; on the South by
Raymundo Laluan (River – before); and on the West by
Carmelita S. Vergara – now.

That on 28 February 1980, a Deed of Extra-Judicial Partition was

entered into by and among TEODORICA SURATOS, REBECCA S. VERGARA,
RONALD S. VERGARA, ANTONIO S. VERGARA, JR., NECITAS S. VERGARA,
CARMELITA S. VERGARA, CARLOS S. VERGARA and VIRGINIA S. VERGARA;
That on 31 May 2016, a Compromise Agreement was executed between
me and Antonio S. Vergara, Jr. whereby the latter offered to donate to me
a Homelot with an area of not less than 100 square meters;

That I agreed and accepted the donation made by Antonio S.

Vergara, Jr., to which I voluntarily surrendered the possession of the
above-mentioned parcel of land together with my entire tenancy rights
after the execution of a Deed of Donation;

That on the same date, 31 May 2016, a Deed of Donation was

executed by Antonio S. Vergara, Jr. giving, transferring and conveying to
me a One Hundred (100) square meters lot, more or less;

the above-mentioned parcels of land were inherited by her husband

Ruperto Abulencia and their son Juan Abulencia;

That subsequently, Ruperto Abulencia married one Pilar Jimenez, to

whom he begot a child named Petra Abulencia;
 That sometime in 1979, Ruperto Abulencia sold by himself the
above-mentioned parcels of land to his daughter Petra Abulencia, without
the consent and conformity of Juan Abulencia;

That the transaction made between Ruperto Abulencia and Petra

Abulencia resulted to co-ownership of the above-mentioned parcels of land
between Juan Abulencia and Petra Abulencia;
That, however, Petra Abulencia surreptitiously and fraudulently
declared that she is the owner of the above-mentioned parcels of land as
evidenced by Tax Declaration Nos. 36-0028-00055 and 36-0028-00056,
respectively, despite the fact that she was aware and knowledgeable that
Juan Abulencia is her co-owner;

That due to the fraudulent declaration of Petra Abulencia, there is

danger that she might sell or in any way dispose or attempt to sell or
dispose the same by virtue of the tax declarations despite the fact that the
property are co-owned between her and Juan Abulencia;

That unless an adverse claim is annotated on the Tax Declarations,

we and our heirs are in jeopardy of being defrauded and deprived of our
just and valid right over the afore-described parcels of land and, as such,
we are executing this Affidavit in support of our request for the annotation
of an Adverse Claim/Precautionary Notice over the parcels of land
described herein;

That we are executing this affidavit to attest to the truth of the

foregoing facts and to request that an Adverse Claim/Precautionary Notice
be annotated in Tax Declaration Nos. 36-0028-00055 and 36-0028-00056
and all other documents relating to the above-mentioned parcels of land
declared in the name of Petra Abulencia.

IN WITNESS WHEREOF, we have hereunto affixed our signatures

this 15th day of October 2018 in the City of Dagupan, Philippines.

LIBERATO T. ABULENCIA LINA A. SOLOMON

Affiant Affiant
OSCA ID No. 013527 OSCA ID No. 17-3974
Issued on 6-7-12 Issued on 2-12-17

SUBSCRIBED AND SWORN TO BEFORE ME this 15th day of

October 2018 in the City of Dagupan, Philippines.

CRESENCIO D. DELA CRUZ, JR.

OIC-Public Attorney III
Pursuant to RA No. 9406