AFFIDAVIT OF MERIT

I, Faye P. Lupa, of legal age, Filipino citizen and a resident of Barangay

Tamag, Vigan City, Ilocos Sur, after having been duly sworn to in accordance
with law, do hereby depose and say that:

 I am the Complainant in the above-caption case filed against, May K.

Pera, Ana P. Lupa, Ben P. Lupa, Carlo P. Lupa, Dexter P. Lupa, and
Emely P. Lupa, the defendants, before the Regional Trial Court of Vigan
City, Ilocos Sur, Philippines;

 MAY LUPA, my mother, was then the absolute and registered owner of
the vacant 450-square meter lot situated at a commercial area in
Quezon Avenue, Vigan City, in the province of Ilocos Sur. She died at the
age of 76, after having been infected from exposure to the novel
coronavirus COVID-19. Being a daughter of May Lupa, I am entitled of
1/6 portion of the said parcel of land.

 That on 12 April 2020, to defray my mothers’ medical and funeral

expenses, Defendants ANA P. LUPA, BEN P. LUPA, CARLO P. LUPA,
DEXTER P. LUPA, and EMELY P. LUPA, executed an Extrajudicial
Settlement of the Intestate Estate with Deed of Absolute Sale over the
above-described commercial lot in favor of Defendant MAY PERA in the
amount of Ten Million Pesos (Php 10,000,000.00).

 I was not given any written notice prior to the agreement to execute a
deed of extrajudicial settlement or partition nor was informed by any of
her siblings of the said extrajudicial partition with simultaneous sale.

 After the expiration of my contract of employment, I returned to the

Philippines as evidenced by my passport and airline ticket.

 During the celebration of my mother’s first death anniversary, I was

informed of the extrajudicial settlement with simultaneous sale of the
commercial lot mentioned above and that the title of the property and
tax declaration was already transferred to Defendant MAY K. PERA.
  I visited Defendant MAY K. PERA at her house on 2 April 2021, and
tried to convince her to buy back the property to which the latter firmly
refused.

 I am entitled to the reliefs demanded in my Complaint and praying that

the extrajudicial settlement of estate with absolute sale entered by the
defendants be declare null and void.

IN TRUTH WHEREOF, I have hereunto affixed my signature below this

May 2, 2021 in Vigan City, Ilocos Sur

( Sgd.)
Faye P. Lupa
Affiant

SUBSCRIBED AND SWORN TO before me on the date and place below,

affiant exhibited to me her Driver’s License bearing numbers A09-98-015476
who avows under penalty of law to the whole truth of the contents of this
document.

WITNESS MY HAND AND SEAL this May 2, 2021 in Vigan City, Ilocos
Sur.

( Sgd.)
Notary Public
Doc No. 06;
Page No. 02;
Book No. 01;
Series of 2021.