Republic of the Philippines )

City of Dagupan ) S.S.

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

AFFIDAVIT OF ADVERSE CLAIM/

PRECAUTIONARY NOTICE

I, HAGIBIS A. FAJARDO, 53 years old, Filipino, and a resident of

Barangay Pogo, Mangaldan, Pangasinan, after having been duly sworn to in
accordance with law, depose and say:

That I am the actual cultivator and possessor over the parcel of land of
ANTONIO S. VERGARA, JR. of Barangay Poblacion, Mangaldan, Pangasinan
particularly described as follows:

“A parcel of land situated in Barangay Pogo, Mangaldan,

Pangasinan, covered by Tax Declaration No. 342 and with an area of
Five Thousand (5,000) square meters, more or less and with market
value of P2,360.00. Bounded on the North by Mariano Guban; on the
East by Nicolas Quinto; on the South by Raymundo Laluan (River –
before); and on the West by Carmelita S. Vergara – now.

That on 31 May 2016, a Compromise Agreement was executed between me

and Antonio S. Vergara, Jr. whereby the latter offered to donate to me a Homelot
with an area of not less than 100 square meters;

That I agreed and accepted the donation made by Antonio S. Vergara, Jr., to
which I voluntarily surrendered the possession of the above-mentioned parcel of
land together with my entire tenancy rights after the execution of a Deed of
Donation;

That on the same date, 31 May 2016, a Deed of Donation was executed by
Antonio S. Vergara, Jr. giving, transferring and conveying to me a One Hundred
(100) square meters lot, more or less;

That I accepted and received the donation made by Antonio S. Vergara, Jr.
on the same date;

That said donation, however, was not materialized after a case was filed
against me for Ejectment by his sister Carmelita Vergara-Tan alleging that the
property donated was owned by the latter;
 That the property donated to me by Antonio S. Vergara, Jr. was in
consideration of being an actual cultivator and possessor of the above-mentioned
parcel of land;

That despite of the above, the 100 square meters mentioned in the Deed of
Donation was not yet given to me by Antonio S. Vergara, Jr;

That an information reached me that Antonio S. Vergara, Jr. was to dispose

his properties in order to escape his obligations to me, namely:

“A parcel of land situated in Barangay Pogo, Mangaldan,

Pangasinan, covered by Tax Declaration No. 342 and with an area of
Five Thousand (5,000) square meters, more or less and with market
value of P2,360.00. Bounded on the North by Mariano Guban; on the
East by Nicolas Quinto; on the South by Raymundo Laluan (River –
before); and on the West by Carmelita S. Vergara – now.

and

“A portion of a parcel of residential land (Plan Psu-200386

L.R. Case No. L-691, LR.C. Records No. N-31814) situated in the
Poblacion, Mangaldan, Pangasinan. Bounded in the NE., by
properties of Marcelino Biala, Heirs of Paula De Guzman and
Victoriano Evangelista; on the SE., by property of Liborio Velasquez;
on the SE., by properties of Pedro Lopez, Antonio Vergara, Heirs of
Julian Cabrera & Daniel Frianeza and Mansueto Gilladogo and on
the SW., by Adan Street (10.00 m. wide) containing an area of ONE
THOUSAND TWO HUNDRED AND FOURTEEN (1,214) SQUARE
METERS, more or less, covered by OCT No. 17642 issued by the
Register of Deeds of Lingayen, Pangasinan declared under Tax
Declaration No. 19484.”

That due to the foregoing, there is danger that Antonio S. Vergara, Jr. might
sell or in any way dispose or attempt to sell or dispose his properties despite the fact
that he has obligations to me with respect to the 100 square meters he donated;

That unless an adverse claim/precautionary notice is annotated on Original

Certificate of Title (OCT) No. 17642, declared under Tax Declaration No. 19484
(for 1,214 sqm) and on Tax Declaration No. 342 (for 5,000 sqm.), I and my 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 I am executing this affidavit to attest to the truth of the foregoing facts
and to request that an Adverse Claim/Precautionary Notice be annotated in OCT
No. 17642, Tax Declaration No. 19484 (for 1,214 sqm) and Tax Declaration No.
342 for (5,000 sqm.), and all other documents relating to the above-mentioned
parcels of land in the name of Antonio S. Vergara, Jr.

IN WITNESS WHEREOF, we have hereunto affixed our signatures this

23rd day of April 2019 in the City of Dagupan, Philippines.

HAGIBIS A. FAJARDO
Affiant
Voter Certification No. 5526-0198A-C2265HAF10000-9

SUBSCRIBED AND SWORN TO BEFORE ME this 23rd day of April

2019 in the City of Dagupan, Philippines.

CRESENCIO D. DELA CRUZ, JR.

OIC-Public Attorney III
Pursuant to RA No. 9406