REPUBLIC OF THE PHILIPPINES)

CITY OF MANILA
) S.S.
x-------------------------------------x

AFFIDAVIT OF ADVERSE CLAIM

I, Mr. X, of legal age, Filipino, single and a resident of 1234 Bonifacio

Street, Kapayapaan Village, Manila City, after having been duly sworn to in
accordance with law, depose and state:

1. That on November 16, 2016, I filed a petition for reconstitution of title with TCT
No. 123456 before the Regional Trial Court of Manila City;

4. That on November 24, 2016, the said petition was granted by the Court and
ordered the cancellation of the old title in the Register of Deeds of Manila, in
lieu of a new title;

5. However, since my request for reconstitution of said title is being barred by an

Affidavit of Non-transfer executed by Mr. Y, I am therefore executing
this Affidavit for the purpose of attesting to the truthfulness of the foregoing
allegations and in support of my request for the annotation of an adverse claim
over the parcel of land covered by the Transfer Certificate of Title No. 123456.

IN WITNESS WHEREOF, I have hereunto set my hand this 26th day

of September 2017 in Quezon City, Metro Manila, Philippines.

Mr. X
Affiant

SUBCRIBED AND SWORN TO before me this 26th day of September

2017 in Quezon City, Metro Manila, Philippines, affiant exhibiting to me her
Philippine Passport No. 123456 issued in Manila on September 19, 2013 and
valid until January 12, 2020.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2013.

Republic of the Philippines

Municipal Trial Court
Branch 5
Manila City

Mr. X, plaintif
Accompanied by his Attorney in fact,
Atty. Afos

-versus-

Mr. Y, Defendant
x-----------------------------------------x

COMPLAINT

Civil Case No. 2

for: Adverse Claim

COMES NOW, the plaintif together with the undersigned counsel to this
most honorable court, MOST RESPECTFULLY STATES THAT;

1.

The Plaintiff is of legal age, married and a resident of 1234 Bonifacio

Street, Kapayapaan Village, Manila City. The Defendant is likewise of legal age,
married and temporary residing at Squatters Land, Manila City.
2.

The Plaintiff is the owner of a parcel of land with TCT No. 123456.

3.

The Defendant maliciously fabricated the fact that the abovementioned

Title has not been lost and therefore cannot be reconstituted.

4.

The Plaintiff has indeed lost the Title and therefore in need of

reconstitution.
5. The defendant willfully and maliciously fabricated facts causing damage and
inconvenience to the plaintiff.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that judgement be rendered in favor of the plaintiff and that
after judgement;

a. The defendant shall be ordered to pay P 120, 000,000 for the Attorneys
Fees and damages.

Such other reliefs and remedies under the premises are likewise prayed
for.

Baguio City, Philippines, this 28th day of December 2016.

Jan Aldrin Afos

Counsel for the Plaintif
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97: Manila
Rm. 4 2/F Manila Boating Center
180 Berkeley Lake, Manila City