Republic of the Philippines

Department of Environment and Natural Resources

DENR-CENRO – APARRI
Region 02, Cagayan, Philippines

N RE: IN THE MATTER OF CANCELLATION

OF FREE PATENT APPLICATION ON LOT
NO. 7048, CAD-1281 D (Lot 5-B), SITUATED
AT CABARITAN, BUGUEY, CAGAYAN, IN
THE NAME OF EVA G. USQUISA

PROTEST NO. ___

HELEN GRACE U. DONATO and EDISON

USQUISA
Protestants,
x--------------------------------------------------------------x

PROTEST
COMES NOW, the protestants, through undersigned counsel, and
unto this Honorable CENRO OFFICER OF DENR-CENRO, APARRI,
CAGAYAN, most respectfully avers:

1) That Protestants, are both Filipino, Citizens, of legal ages, married,

and residents of Cabaritan, Buguey, Cagayan;

2) That the protestee-applicant is a resident of Cabaritan, Buguey,

Cagayan, where he may be served with summons, writ and other
processes;

3) That the subject matter of this protest is a parcel of land that

LOT NO. 7048, CAD-1281 D (Lot 5-B), situated at Cabaritan,
Buguey, Cagayan;

4) Upon verification with CENRO, Aparri, Cagayan, the protestant

learned that their sister Eva Usquisa had filed a Free Patent
Application on the abovementioned lot;

5) That the protestant signifies his objection to the Free Patent

Application of LOT NO. 7048, CAD-1281 D (Lot 5-B), as they are
co-owners of the above –mentioned parcel of land subject of the
Free patent Application;

6) That the protestant’s mother Corazon G. Usquisa bought the

subject property from Marcelo Tapalgo, who is the legal heir of
Tomas Binoya, the original survey claimant;
 7) That after the death of his predecessor-in-interest, the protestee-
applicant and protestants agreed to divide the subject property
among them;

8) The protestee-applicant enticed the protestants to execute Joint

Affidavit of Quitclaim on the condition that the protestee will give
her consent to the sale of another co-owned property, particularly
Lot No. 7048, CAD 1281-D (Lot 5-B per survey list);

9) However, after the execution of the said Affidavit of Quitclaim, the

protestee-applicant objected to the sale of Lot No. 7048, CAD
1281-D (Lot 5-B per survey list). Worse, she claimed that she owns
the entirety of the property;

10) Would it not for the misrepresentation of the Protestee-Applicant,

the protestants should not have signed the Affidavit of Quitclaim;

11) Clearly, the consent of the protestants was vitiated, hence, the
Affidavit of Quitclaim should be disregarded and the Free Patent
Application of the protestee-applicant should be denied.

12) That to further prove the claim of the protestant, the Joint Affidavit
of Evangelyn P. Custodio and Nanie J. Agno is hereto attached as
“Annexed B”;

PRAYER
WHEREFORE, it is most respectfully prayed before this Honorable
Department of Environment and Natural Resources (CENRO) to reject
the application for titling or Free Patent Application of EVA G. USQUISA
on Lot No. 7048, CAD 1281-D (Lot 5-B per survey list) for being not the
proper party to apply the same as the latter is only a co-owner of the
subject lot;

Other relief’s just and equitable are likewise prayed for.

Respectfully submitted.

__________________ at Sta. Teresita-Aparri, Cagayan, Philippines.

Atty. Orlando B. Bareng Jr.

Door 1, Martinez Building, Centro East, Sta. Teresita, Cagayan
Roll No. 73345, 06-19-2019
PTR No. 13830781/ 01-08-2024/ CGYN
IBP Mem. O.R No. 398233/ 01-08/2024/CGYN
Cp. No: 0905-6928-114
barengorlando@yahoo.com.ph
MCLE Comp. No. VII-0022946
 VERIFICATION

HELEN GRACE U. DONATO and EDISON USQUISA , of legal ages,

Filipino citizens, and with residence at Cabaritan, Buguey, Cagayan, after
having been duly sworn to in accordance with law do hereby depose and
state that:

1. We are the protestant in the above-entitled case;

2. We have caused the preparation of the foregoing Protest and that

based on our own personal knowledge and authentic records, the facts
stated therein is true and correct;

3. The pleading is not filed to harass, cause unnecessary delay, or

needlessly increase the cost of litigation;

4. The factual allegations therein have evidentiary support or, if

specifically so identified, will likewise have evidentiary support after
a reasonable opportunity for discovery;

5. We hereby certify that no petition or proceeding of a similar nature

has been filed with any office, court or with the Court of Appeals or
the Supreme Court or any government agency or instrumentality for
that matter, and should we learn of any such case being pending or
filed with such agencies or courts above-mentioned, we undertake to
inform the Honorable Court or any government instrumentalities
having jurisdiction of this case of the existence or pendency of such
proceeding or action, within five (5) calendar days from knowledge of
such fact

6. We attest to the truthfulness of the foregoing facts;

7. Affiants further sayeth naught.

IN WITNESS WHEREOF, I have hereunto set my hand this _____

day of __________________, 2023 in ______________________.

Protestant

HELEN GRACE U. DONATO EDISON USQUISA

ID:___________________________ ID:______________
SUBSCRIBED AND SWORN to before me this _____ day of
________________ in _____________________. Affiant-Protestants
personally appeared and exhibited to me his above written Identification
card just below their names as competent proof of his identity.

Doc. No. : ______;

Page No. : ______;
Book No.: ______;
Series of 2023.