Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
BRANCH 5
Tuguegarao City, Cagayan

IN RE: PETITION FOR THE

CANCELLATION OF
ADVERSE CLAIM
INVOLVING LOT NO. 1121997,
COVERED BY TRANSFER
CERTIFICATE OF TITLE NO.
9973213 OF THE REGISTRY
OF DEEDS FOR THE
PROVINCE OF ISABELA

MSC. CAD CASE No. 73839

NODICAKES QEROBS,
Petitioner,

GLENNDA PASCA and THE

REGISTER OF DEEDS FOR
THE PROVINCE OF
ISABEALA
Respondent.

PETITION

PETITIONER, by and through the undersigned counsel and unto

this Honorable Court most respectfully depose and aver that:

1. Petitioner Nodicakes G. Querobs is of legal age, Filipino

citizen, widow and a resident of Woodcrest Subdivision, Tagaran,
Cauayan City, Isabela. She can be served with notices, orders, judgment
writs and other court processes of the Honorable Court through the
undersigned counsel whose address is indicated herein-under;

2. Respondents Glennda Pasca and The Registry of Deeds for

The Province of Isabela, they are represented in this case by their
attorney-in-fact Chrissy Boi Corts by virtue of a special power of
attorney herewith attached as ANNEX “A”. The latter is a Filipino
Citizen, of legal age, married and a resident of San Fermin, Cauayan
City, Isabela, Philippines, where he can be served with summons and
other court processes;
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Page 2 of 3

3. Register of Deeds of the Province of Isabela, is the

government agency tasked with the registration and custody of land
titles, among others, and may be served with summons and other
processes of this Honorable Court at LRA Building;

4. Petitioner is the true and registered owner of a parcel of

land covered by Transfer Certificate of Title number 9973213, more
particularly described as follows:

Transfer Certificate of Title No. 9973213

“A parcel of land (Lot 1121997, of the subdivision

survey, Psd-124568 being a portion of Lot 54831657,
situated in the Cauayan City, Province Isabela (sic). x x x
Containing an area of 8000 SQUARE METERS x x x”

A photocopy of the Transfer Certificate of Title of the afore-

described parcel of land is hereto attached as ANNEX “B” and is made
an integral part hereof.

5. That annotated on said Transfer Certificate of Title No.

9973213 is the entry, to wit:

Transfer Certificate of Title No. 9973213

Entry No. 2165875 . . . . . . . . . . . . . . . . . . . ADVERSE CLAIM

NOTICE OF ADVERSE CLAIM executed by Nodicakes
Qerobs who assert certain rights and privilege over this property
in accordance with Law.
Date of Inscription: 11/21/2020

6. The Respondents who executed the adverse claim in the

subject property were Assignees of the ½ of the area of the entire
properties covering TCT. No. 5487615;

7. The Petitioner will now subject the property to a Sale in

which the Respondents through their attorney-in-fact secured a
negotiation for their one-half share;

8. The Respondents through their attorney-in-fact executed an

Affidavit of Cancellation of Adverse Claim in TCT No. 5487615 to enable
them to have a free disposal thru Sale of the subject property. Copy of
the affidavit is hereby attached as ANNEX “C”;

9. The annotation of the adverse claim on the title is an

unnecessary encumbrance which is derogatory to the title and
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Page 3 of 3

ownership of the Petitioner; as such it is imperative that the adverse

claim be cancelled;

10. Moreover, this unnecessary encumbrance of adverse claim

was annotated now for more than thirty (30) days from its entry, and
likewise imperative that the adverse claim be cancelled.

PRAYER

WHEREFORE, pursuant to law, and in view of the fact that the

adverse claim has lost its effectivity it is respectfully prayed that after
due proceedings, an order be entered directing the Register of Deeds of
Transfer to cancel Entry no. 9973213 as annotated on Transfer
Certificate of Title No. 8756215.

Such other reliefs which may be just and equitable under the
premises are likewise prayed for.

Cauayan City, Isabela, January 18, 2023.

ATTY. IAN JOHN L. TATTAO

Counsel for the Petitioner

Copy furnished:

OFFICE OF THE PROVINCIAL REGISTER OF DEEDS

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