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Republic of the Philippines )

City of Dagupan ) S.S.


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AFFIDAVIT OF ADVERSE CLAIM/


PRECAUTIONARY NOTICE

We, SPS. MARIA ANGELICA & BENJAMIN ZAMUDIO and SPS.


ROGER & ROSITA ROCABERTE, all of legal age, Filipinos, and all
residents of Barangay Bigbiga, San Fabian, Pangasinan, after having been
duly sworn to in accordance with law, depose and say:

That we bought certain parcels of land from RODOLFO L. MENDEZ


a.k.a. RUDY located in Barangay Bigbiga, San Fabian, Pangasinan with an
area of 250 square meters and 400 square meters, respectively. Copies of the
Reciboan Ti Ginatang Nga Dga are hereto attached as ANNEX A and B,
respectively.

Sometime in 2013, we learned that RODOLFO L. MENDEZ and his


siblings sold the property they inherited from their parent SIMPLICIO
MENDEZ.

We confronted RODOLFO L. MENDEZ about the property he sold to us.


He assured us that the portions of the property we bought were not included
in the abovementioned transaction.

We learned later that the property we bought was being claimed by


CARLOS E. CHAN alleging that he also bought the same.

Thereafter, CARLOS E. CHAN immediately transferred and had it


registered into his name without even informing us. In fact, our houses were
already built thereon, and CARLOS E. CHAN was aware of the fact that we
bought portions thereof.

That due to the fraudulent acts of CARLOS E. CHAN, there is danger


that she might sell or in any way dispose or attempt to sell or dispose the same
by virtue of the TCT No. 026-2014002135 despite the fact that we are owners
of the portions thereof.

That unless an adverse claim is annotated on the TCT No. 026-


2014002135, we and our heirs are in jeopardy of being defrauded and deprived
of our just and valid right over the afore-described parcels of land and, as such,
we are executing this Affidavit in support of our request for the annotation of
an Adverse Claim/Precautionary Notice over the parcels of land described
herein;
That we are executing this affidavit to attest to the truth of the foregoing
facts and to request that an Adverse Claim/Precautionary Notice be annotated
in Transfer Certificate of Title No. 026-2014-4002135 and all other documents
relating to the above-mentioned parcel of land declared in the name of Carlos
E. Chan.

IN WITNESS WHEREOF, we have hereunto affixed our signatures


this 7th day of January 2019 in the City of Dagupan, Philippines.

MARIA ANGELICA ZAMUDIO BENJAMIN ZAMUDIO


Affiant Affiant

ROGER ROCABERTE ROSITA ROCABERTE


Affiant Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this ____ day of


January 2019 in the City of Dagupan, Philippines.

Administering Officer

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