ADVERSE CLAIM

I, ARNULFO INTERIOR, of legal age, Filipino, married, and a resident of Tuguegarao

City, Cagayan, after having been duly sworn to in accordance with the law, states THAT:

1. I am the former registered owner of a parcel of land located at Larion Alto, Tuguegarao
City, Cagayan, then covered and embraced under Transfer Certificate of Title No. T-
134761 which was part of the Estate of the late Leonardo Lavadia that was the subject of
suit before Branch 4 of the Regional Trial Court of Tuguegarao City, Cagayan, docketed as
Special Proceeding No. 114, which case is still currently heard to this date;

2. The current registered owners of the land as appearing in the records of the Registry of
Deeds of Cagayan are Spouses Atty. Dominador Pauig and Judge Vilma Pauig per
Transfer Certificate of Title No. T-163853, the afore-named having consolidated ownership
thereof in their favor by virtue of a Decision dated July 18, 2008 rendered in Civil Case No.
6684 by Regional Trial Court, Branch 5, Tuguegarao City, Cagayan, entitled Sps.
Dominador Pauig and Vilma Pauig vs. Arnulfo Interior, which Decision I did not actually
receive up to this date and which Decision I came to know recently;

2.1 I have in October 27, 2003 executed a Pacto De Retro Sale in favor of Atty. Vilma
Pauig (the same Judge Pauig mentioned above) which became the basis of
Spouses Pauig to file a consolidation case;

3. Atty. Domindor Pauig, the husband of Judge Vilma Pauig, entered his appearance and
acted as my lawyer in Special Proceedings No. 114 which case is still pending to date and
that Atty. Pauig is asking the court in that case that his attorney’s lien be annotated in
whatever claim I might have in the said case;

4. The transfer of ownership of the afore-mentioned real property is clearly prohibited by

Article 1491 of Civil Code of the Philippines that specifically prohibits lawyers from
acquiring either by purchase or assignment the property or rights involved which are the
object of the litigation in which they intervene by virtue of their profession;

5. I intent to file a case for the annulment the aforesaid purchase made by Judge Vilma
Pauig since it is prohibited by law and that I want the property to be reconveyed in my
favor;

6. I am executing this affidavit to attest to the truthfulness of the foregoing facts and for
the purpose of causing the annotation of this adverse claim to Transfer Certificate of Title
No. T-163853 in the name of Spouses Domingo Pauig and Vilma Pauig.

ARNULFO INTERIOR
Republic of the Philippines )
Province of Cagayan ) SS
Tuguegarao City )

SUBSCRIBED AND SWORN to before me this 5 th day of September 2008 at

Tuguegarao City, Cagayan.

Doc. No. ______;

Page No. ______;
Book No. _____;
Series of 2008