REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
LAND REGISTRATION AUTHORITY
QUEZON CITY
REGISTER OF DEEDS FOR QUEZON CITY

REPUBLIC OF THE PHILLIPPINES)

IN THE CITY OF MAKATI ) S.S.
x…………………………………………………….x

AFFIDAVIT OF ADVERSE CLAIM

AND NOTICE OF LIS PENDENS

I, RONELL M. ABARA, of legal age, Filipino Citizen, and

presently residing at AMVEL Mansions, Dr. A Santos Avenue, Brgy.
San Dionisio, Sucat, Paranaque City, after having been duly sworn
to in accordance with law, do hereby depose and state that:

I. ADVERSE CLAIM

1. I am filing an ADVERSE CLAIM, over two (2) parcels of land

respectively covered by Transfer Certificate of Title No.
004-2014006627 and by Transfer Certificate Of Title No.
004-2014006628 of the Registry of Deeds of Quezon City.

2. I am the purchaser in good faith and for value of the aforesaid

two (2) parcels of land registered in the name of SPOUSES
DANILO SANTIAGO and MARINEL SANTIAGO who both
live at 19 Andromeda St., Acropolis Green Subdivision,
Quezon City for the amount of SIXTEEN MILLION PESOS
(P 16, 000, 000.00) duly paid and delivered to the Spouses
Santiago.

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3. On June 19, 2014, SPOUSES DANILO and MARINEL
SANTIAGO executed and gave to me a DEED OF ABSOLUTE
SALE OF PARCEL OF LAND along with the OWNER’S
DUPLICATE COPY OF Transfer Certificate Of Title No.
004-2014006628 registered in the name of DANILO B.
SANTIAGO married to MARINEL B. SANTIAGO.

4. On even date, while I was at the 23rd floor, G-T Tower, Ayala
Avenue, Makati City, I handed the amount of P8, 000,000.00
to MS. IMELDA ARAI, who in turn, handed over the same to
MARINEL B. SANTIAGO, as payment for the property
covered by Transfer Certificate of Title No. 004-2014006628.

5. Subsequently, another sale was made for the similar price of

EIGHT MILLION PESOS (P8, 000,000.00) and the
SPOUSES executed again a DEED OF ABSOLUTE SALE OF
PARCEL OF LAND the subject of which is the parcel of land
covered by Transfer Certificate of Title No. 004-2014006627
duly registered in the name of DANILO B. SANTIAGO
married to MARINEL SANTIAGO.

6. For purposes of complying with the requirement of the real

property descriptions, attached herewith and made as integral
part of this Affidavit are the OWNER’S DUPLICATE COPY
for Transfer Certificate of Title No. 004-2014006627
(ANNEX A) and for and OWNER’S DUPLICATE COPY for
Transfer Certificate Of Title No. 004-2014006628 (ANNEX
B) given by the SPOUSES to herein Affiant which contain the
complete technical descriptions of the two (2) properties.

7. Likewise, copies of the two (2) DEEDS OF ABSOLUTE SALE

are hereto appended to this Affidavit of Adverse Claim as
ANNEXES C and D, respectively.

8. Further, herein claimant states that for purposes of all notices

in connection with the present ADVERSE CLAIM that may be

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 served upon him, service thereof shall be made to the address
of claimant as above-stated.

9. Hence, pursuant to the two (2) consecutive sales made, the

SPOUSES DANILO B. SANTIAGO and MARINEL
SANTIAGO have since relinquished all their rights, interests
and participation over the aforesaid parcels of land in favor of
herein claimant and his heirs.

10. However, it has come to claimant’s knowledge that the

SPOUSES are presently claiming to still have an interest over
the aforementioned parcels of land and are attempting to sell
or dispose of the same despite the fact that they have already
conveyed all their rights and interests thereon to herein
claimant and to his heirs.

11. Unless due annotations of adverse claims are made on the two
afore-described Transfer Certificates of Title, the claimant and
his heirs are in danger of being defrauded and deprived of
their rights over the two parcels of land.

II. NOTICE OF LIS PENDENS

12. Notice is hereby given to the Register of Deeds, Quezon City

that CRIMINAL CASE NO. 15-3016 and CRIMINAL CASE NO.
15-3017 have been filed against SPOUSES DANILO and
MARINEL SANTIAGO for two (2) counts of Estafa Thru
Falsification of Public Document before the Regional Trial
Court, Branch 137 of Makati City involving the Transfer
Certificate of Titles of the aforesaid two parcels of land.
Appended herewith as Annex E is a copy of the Joint Decision
rendered by RTC Makati.

13. Presently, the Joint Decision is under appeal before the Court
of Appeals.

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 I am executing this Affidavit to attest to the truth and veracity
of the foregoing statement, in support of the annotation by the
Register of Deeds, Quezon City of my ADVERSE CLAIMS over
Transfer Certificate of Title No. 004-2014006627 and Transfer
Certificate of Title No. 004-2014006628 as well as the due
annotation of NOTICE OF LIS PENDENS.

IN WITNESS WHEREOF, I have hereunto set my hand this

________ day of June 2019 at Makati City, Metro Manila, Philippines.

____________________________
RONELL M. ABARA
Affiant

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