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Adverse Claim Petition
Adverse Claim Petition
PETITION
With all due respect to the Honorable Court. Petitioners through the
undersigned counsel most respectfully state that:
1. Petitioners are both of legal age, Filipinos, and residents of No. 14 Tacay
Road, Pinsao Proper, Baguio City, Philippines. They 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.
5. Petitioners are the true and registered owners of a certain parcel of land
which is covered by Transfer Certificate of Title with number 018-2011001191
and more particularly described as follows:
9.
10. Previous to the parties sale on April 2, 2011, Petitioners verified with the
Registry of Deeds for Baguio City the status of the
11. Before and during thePetitioners bought the subject property from Tito
J. Rimando through his attorney-in-fact Richard Banana, which is, a portion
of a parcel of land owned by Tito J. Rimando which was covered by Transfer
Certificate of Title No. 018-2010002760;
12. When petitioners bought the property on April 2, 2011, they checked the
file copy of the TCT No. 018-2010002760 to the Registry of Deeds of
Petition
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Baguio City and found no adverse claims from respondents, and even
when petitioners caused the annotation of Certificate Authorizing
Registration issued by the BIR, on April 08, 2011, there were no
annotations of any encumbrance of adverse claims from the
respondents;
13. Petitioners had found out of these adverse claims by respondents only
when the new Transfer Certificate of Title in their name was issued by
the Registry of Deeds of Baguio;
14.
PRAYER
WHEREFORE, pursuant to law, and in view of the fact that the adverse claim
has lost its effectively it is respectfully prayed that after due proceedings, an order be
entered directing the Register of Deeds of Baguio City to cancel Entry no.
___________ as annotated on Transfer Certificate of Title No. _______________
and to order the respondent ___________________ to pay 15,000.00 as attorneys
fees and cost for this suit;
Such other relief’s which may be just and equitable under the premises are
likewise prayed for.