REPUBLIC OF THE PHILIPPINES)

PROVINCE OF CAGAYAN ) S.S.

CITY OF TUGUEGARAO )

AFFIDAVIT OF ADVERSE CLAIM

I, ERNESTO C. TAN, of legal age, Filipino, single and a resident of

Masipag, City of Venus, after having been duly sworn to in accordance with
law do hereby depose and state that:

1. On January 5, 2014, Esting borrowed the amount of Two Million

Pesos (Php2,000,000.00);

2. In lieu of the said amount, a real estate mortgage was executed on

in my favor January 10, 2014 with a parcel of land with house
erected therein given as a security particularly described as
follows:

A parcel of land. (Lot F of the sebd. Plan Psd-04-040359

being a portion of Psu-207939, LRC Rec. No.), situated in
the Brgy. Of Makaulaw, City of Venus, Prov. Of Cagayan.
Bounded on the SW. along line 1-2 by Lot E of the subd.
Plan; on the NW along line 2-3 by Lot 11050, Cad-609-D,
City of Venus Cad; on the NE. along line 3-4 by Lot G; on
the SE along line 4-1 by Lot I (Road), both of the subd.
Plan; containing an area of Five Hundred (500) square
meters more or less and covered by Transfer Certificate
of Title No. M-105187 issued by the Register of Deeds of
City of Venus, Cagayan;

(Attached hereto is the copy of the Real Estate Mortgage and is

hereby marked as “Annex 1”)

3. The real estate mortgage provides that the amount borrowed shall
be paid within the period of five (5) years or until January 10, 2019.
However, up to date despite repeated demands, no payment has
ever been made;

4. To my surprise as per verification with the Office of the Register of

Deeds, a Memorandum of Encumbrance with Entry Number 1888
(Deed of Donation) has been ascribed at the back of Transfer
Certificate of Title No. M-105187;

5. To protect my interest over the subject property, I am executing

this affidavit in good faith, attesting to its veracity and for the
purpose of filing a case for the revocation of a Deed of Donation in
our courts of law.

AFFIANT FURTHER SAYETH NAUGHT.

Tuguegarao City, Cagayan, October _____, 2005

MELINDA C. LUMABAN
Affiant
SUBSCRIBED AND SWORN to before me this _______ day of
October, 2005 at _______________________________.

Doc.______
Page _____ NOTARY PUBLIC
Book _____
Series of 2005