Republic of the Philippines )

Quezon City ) S.S.

x-------------x

AFFIDAVIT OF ADVERSE CLAIM

I, ANGELO RAMOS GILBUENA, of legal age, Filipino, married,

and a resident of No. 10 18th Ave., Murphy, Cubao, Quezon City, after
having been sworn to in accordance with law, depose and say:

1. That I am one of the heirs of the late MANUELA D. RAMOS -

GILBUENA.

2. That when my mother died on March 16, 20191, where she left
one (1) unit of house and lot, our family home, located at No. 10
18th Ave., Murphy, Cubao, Quezon City, covered by Transfer
Certificate of Title (TCT) No. N-1953682;

3. On August 9, 2019, I was about to check the property left by my

mother, and since the said property is located inside a gated
townhouse, the security guard was prevented me to enter the
townhouse and the instruction was came to my maternal aunt,
Stella Ramos Reiss, because the latter is the new owner of the said
property;

4. That I checked the title of the property of my deceased mother

before the Registry Deeds of Quezon City, and to my surprise, the
land title (TCT No. N-195368) involving the property of my
deceased mother was already cancelled, and now the same is
under the name of my aunt Stella R. Reiss (under TCT No. 004-
2017003727)3 on the basis of a Deed of Absolute Sale allegedly
executed by my mother dated 31 January 2017;

5. That the alleged Deed of Absolute Sale was executed in favor of

the Stella R. Reiss, which document is more particularly identified
as Document No. 300, Page No. 60, Book No. I, Series of 2017,
notarized by ATTY. DULCISIMO G. HINNAY JR. a notary public
for and in Quezon City, and a copy of which is attached herein as
Annex “D” and “D-1”.

6. The Deed of Absolute Sale was dubious because, as far as my

recollection is concerned, there is no way that my mother could
appear before the said notary public in Quezon City, on 31 January
2017, on the ground that during that time, she was staying in my
house in Bulacan since she was already, at the time under my care
and custody, as she suffered parkinson’s disease that she always
needed an accompany in all her tra

1
See attached photocopy of Death Certificate as Annex “A”
2
See Attached photocopy of TCT with No. N-195368 as Annex “B”
3
See Annex attached TCT with No. 004-2017003727 as Annex “C”
 7. . vel;

8. On the other hand, the purported signature of my mother in the

Deed of Absolute Sale as compared to the signature of my mother
reflects in her government issued IDs were not the same which
prompted me to raising doubt as to the authenticity of the said
document;

9. Assuming, without admitting the same, that the sale was true,
there was no single occasion that I learn that my mother received
cash amounting Four Hundred Thousand Pesos (Php.
400,000.00) from my aunt Stella R. Reiss.

10. In fact, it was me, and my other siblings were the ones who
contributed money to funds the medication expenses of our
mother, including her funeral expenses upon her demise.

11. My mother would not sell our house in favor of my aunt Stella
R. Reiss not only because of the unconscionable amount of
consideration involved but the said property has been our family
home and it has sentimental value and lot of good family memories
to my mother;

12. That being defrauded and deprived of our just and valid right
over the above described property and, as such, I am executing
this Affidavit in support of my request for the annotation of an
adverse claim over the parcel of land described herein.

FURTHER AFFIANT SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand this 15th

day of August 2019, in the Quezon City, Philippines.

ANGELO RAMOS GILBUENA

Affiant

SUBSCRIBED AND SWORN to before me this 15th day of August 2019, at

Quezon City, affiant exhibited to me his LTO issued Driver’s License ID with
No.N02-91-158449, WITH Expiry Date: 2023/04/21.

NOTARY PUBLIC

Doc. No. ____

Page No. ____
Book No. ____
Series of 2019.