Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
BRANCH ______
Baguio City
IN RE: PETITION FOR THE
CANCELLATION OF ADVERSE CLAIM IN
TCT NO. 018-2011001191
SPS. DWIGHT C. BLACK and SOFIA S.
RELLAMA-BLACK,
Petitioners,
LRC CASE No. ________
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.
2. Respondent LYNNIE ANTHONETTE G. VINO, is of legal age, married,
Filipino citizen, and with postal address at Lot 9 Block 1 Eagle Crest
Subdivision, Bakakeng, Baguio City, Philippines and she may be served with
summons and other court processes at the given address;
3. Respondents spouses EDWIN G. VALENCIA and NANCY A. VALENCIA,
both of legal age, Filipino citizens, and with postal address at No. 40 Upper
Malvar Street, Aurora Hill, Baguio City, Philippines, where they may be served
summons and other court processes of the Honorable court;
4. The office of the Register of Deeds of Baguio City is impleaded as a necessary party, with
official address at the City Hall, Baguio City where it
may be served with summons and other court processes of the Honorable
court;
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:
Transfer Certificate of Title No. 018-2011001191
“A PARCEL OF LAND (LOT 2-B OF THE SUBDIVISION PLAN (LRA)
PSD-420673 APPROVED AS A NON-SUBDIVISION PROJECT, BEING
A PORTION OF LOT 2, (LRC) PCS-2636 CIVIL RESERVATION 211,
SITUATED ON THE BARRIO OF RES. SEC. “J”, CITY OF BAGUIO,
ISLAND OF LUZON. BOUNDED ON THE NE., AT POINTS 4 TO 1
BY LOT-B-4-C, (LRC) PSD-24699; ON THE SE., AT POINTS 1 TO 2
BY LOT 2-A OF THE SUBDIVISION PLAN; ON THE SW., AT POINTS
2 TO 3 BY (LRC) PCS-2636; ON THE NW., ALONG LINE 3 TO 4 BY
PROPERTY OF GEROLD LINO PISTOLA. BEGINNING AT A POINT
MARKED “1” ON PLAN. BEING N. 70 DEG. 32’ W., 1928.63 M.
FROM TRI. STA. “BOYD” BAGUIO TOWNSITE; THENCE x x x;
CONTAINING AN AREA OF THREE HUNDRED SIXTY FOUR
SQUARE METERS (364) SQ. M.), MORE OR LESS. x x x.
A photocopy of the Transfer Certificate of Title of the aforedescribed parcel of
land is hereto attached as ANNEX “A” and is made an integral part hereof.
6. The subject property was acquired by Petitioners from Tito J. Rimando
through the latter’s Attorney-in-Fact, Richard F. Banaña on April 2, 2011 as
evidenced by a “Deed of Sale of a Portion of Registered Land” executed by the
latter in Petitioners’ favor. The property acquired by Petitioners
7.
8. A photocopy of the aforementioned “Deed of Sale” is hereto attached as
ANNEX “B” and is made an integral part hereof.
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