REPUBLIC OF THE PHILIPPINES)

) s. s.

AFFIDAVIT OF ADVERSE CLAIM

I, FLORDELIZA ESTADILLA HAYAKAWA, of legal age, married,

Filipino and with residential and postal address at Blk. 5 Lot 1 Mimosa
St., St. Joseph Village, Phase 3, Brgy. Langgam, San Pedro City, Laguna,
after having been duly sworn in accordance with law, hereby depose and
state:

1. That I am the registered owner of a real property

located at located Lot 1 Blk. 2 Villa Olympia Ave., San
Vicente, San Pedro, Laguna and covered by Transfer
Certificate of Title No. T-263007, more particularly
described as follows:

TCT NO. T-263007

“A parcel of land (Lot 1

Block 2 of the subd. Plan, Psd-04-
011885, being a portion of Lot 6-
C(LRC) Psd-298514, LRC Rec.
No.), situated in the Bo. Of San
Vicente, Mun. of San Pedro, Prov.
Of Laguna. Bounded on the NE.,
along line 1-2 by Lot 3, Blk. 2, of
the subd. Plan; on the SE., along
line 2-3 by Lot 6-B(LRC) Psd-
2985514 (Existing Road) 15.00m.
wide; on the SW., along lines 3-4-
5 by Road Lot 1 and on the NW.,
along line 5-1 by Lot 2, Blk. 2, of
the subd. Plan. Beginning at a
point marked “1” on plan, being
S. 39deg. 4’W., 2979.31m. from
BLLM 1, Mun. of San Pedro,
Laguna; THENCE S.14deg. 48’E.,
15.00. to point 2; S.75deg. 12’W.,
11.67m. to point 3; N.59deg.
43’W., 4.01m. to point 4; N.14deg,
48’W., 12.17m. to point 5; (OVER)
N.75deg. 13’E.,14.50m. to the
point of beginning, containing an
area of TWO HUNDRED
THRITEEN(213)SQUARE METERS,
more or less.”

2. That, on November 22, 2018, while I was in Japan, I

was shocked to hear from my sister that my
aforementioned property was already sold by my niece
ARLENE PAGAYUNAN to the spouses Gerardo and
Evangeline Camacho without my knowledge and
 consent. I immediately decided to come home to the
Philippines from Japan to verify the news;

3. Upon arriving on December 10, 2018, I immediately

inspected the title given to me by my niece Arlene
Pagayunan. Thereafter, together with my sister Fe
Negrosa, we brought the title to the Register of Deeds
of Calamba, Laguna and we were told that the title was
fake. The Register of Deeds then confiscated the fake
title and issued an Acknowledgment Receipt dated
December 27, 2018 stating among others that the
owner’s duplicate copies of T-263007 was confiscated
by them for being “patently fake”. Copy of the
Acknowledgment Receipt with the attached fake title is
hereto attached and marked as Annexes “A” with
sub-markings;

4. That, upon further inquiry with the Register of Deeds,

we discovered that my niece was able to enter into a
sales contract with the spouses Camacho by virtue of
a forged and simulated Special Power of Attorney
(SPA). As a result, the spouses Camacho have the
original title in their possession and have already
secured a Certificate Authorizing Registration (CAR)
from the Bureau of Internal Revenue in order to
transfer the subject property in their name. My sister
was able to secure the purported SPA and the Deed of
Absolute Sale between Arlene Pagayunan and the
spouses Camacho which shows that the property
covered by TCT NO. 263007 was sold to the latter in
the amount of PESOS: THREE HUNDRED
THOUSAND and 00/100 (Php300,000.00) on
December 13, 2018 in Manila. Copies of the Deed of
Sale, Special Power of Attorney and the Certificate
Authorizing Registration (CAR) are hereto attached and
marked as Annexes “B,” “C,” and “D,” respectively;

5. That, I vehemently and categorically deny that I have

sold the aforementioned real property to any person. I
also did not authorize my niece Arlene Pagayunan to
sell the same nor did I execute a Special Power of
Attorney in her favor. My signature appearing therein
was forged and not my signature;

6. That, I intend to file a complaint against my niece

Arlene Pagayunan and also an action to nullify the
sale. However, as the filing of the said criminal and/or
civil cases will take some time and for fear that the
“buyers” may be able to sell and dispose my
aforementioned real property, I am executing this
affidavit of adverse claim to request that an adverse
claim be annotated at the encumbrance portion on the
real property covered by TCT No. T-263007, to protect
my rights and interests;

2
 7. I am executing this Affidavit to attest to the
truthfulness and correctness of the foregoing.

IN WITNESS WHEREOF, I have hereunto affixed my name and

signature this 28th day of August 2019 at San Pedro City, Laguna.

FLORDELIZA ESTADILLA HAYAKAWA

Affiant

SUBSCRIBED AND SWORN TO before me this 28th day of August

2019 at San Pedro City, Laguna, affiant exhibiting to me her
Identification Card/Document bearing number ____________.

Doc No._______
Page No._______
Book No._______
Series of 2019.