REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 107
Quezon City

PERCIVAL CHAN,
Plaintiff
Civil Case No. B-1234
-versus- FOR: Annulment of Deed of
Sale, Cancel Transfer Certificate
of Title, Reconveyance and Damages

JOSE DY AND EVA TAN,

Defendant

X—---------------------------------X

COMPLAINT

STATEMENT OF THE CASE

This is an action for recovery of a 225 square meter lot located in

Blk 1, Lot 12, Brgy. Diliman, Quezon City which formerly has an
assessed value of One Million Pesos (Php 1,000,000) now registered as
TCT No. 12345 under the name of the defendant, Jose Dy, through the
annulment of Deed of Sale, cancellation of Transfer Certificate of Title
(TCT), reconveyance, and damages brought forth by the plaintiff,
Percival Chan, on the grounds of: 1) Fraud, 2) Estafa, 3) Falsification of
Documents, 4) Bad Faith and, 5) Grave Misconduct which are in contrary
to the provisions of Articles 449, 450, 1170 of the New Civil Code, an
offense under the Revised Penal Code, and contrary to the Code of
Professional Responsibility.

ULTIMATE FACTS
The grounds for this action are as follows:

I. The plaintiff asserts that the defendant, Eva Tan, unlawfully and
illegally sold a parcel of land (Lot 143143) situated in BLK 1, LOT
12, Pinya Street, Brgy. Diliman, Quezon City, which was originally
and lawfully owned by the plaintiff. The sale was purportedly
facilitated with fraud through a falsified Notarized Special Power
of Attorney (SPA) and other fraudulent documents, without the
plaintiff's knowledge or consent, to the damage and injury of the
latter.

II. The plaintiff alleges that the defendant, Jose Dy, acted in bad faith
by participating in the fraudulent transaction by purchasing the
property from Eva Tan, well-aware of the fraudulent means
employed, the illegitimacy of the sale, and the plaintiff's rightful
 ownership, which constitutes a grave misconduct on his part as a
lawyer.

III. The plaintiff emphasizes that the sale was impossible to execute as
he was residing in Hawaii, USA, during the purported sale period
and did not authorize Eva Tan to sell the property. Furthermore,
the plaintiff asserts that Eva Tan falsely declared his death due to
COVID-19 in 2020, which has caused injury and damage to the
plaintiff.

IV. The plaintiff seeks the annulment of the Deed of Sale, cancellation
of Transfer Certificate of Title No. 12345, reconveyance of the
subject property, and pray for appropriate damages as may be
determined by the court.

Plaintiff, PERCIVAL CHAN, by the undersigned counsel and to this

Honorable Court, respectfully states that:

THE PARTIES

1. Plaintiff, PERCIVAL CHAN, is of legal age, single, Filipino citizen

and a resident of BLK 1, LOT 12, Pinya Street, Brgy. Diliman,
Quezon City;

2. For purposes of this action, the plaintiff may be served with orders,
issuances, and other court processes through its counsel, ATTY.
JOHAN ANDRE B. ACUBA with address at #143 Paseo Street,
Alabang, Muntinlupa City.

3. Defendants JOSE DY, is of legal age, single, Filipino citizen, a

lawyer, and a resident of BLK 1, LOT 13, Pinya Street, Brgy. Diliman,
Quezon City, and EVA TAN, is of legal age, single, Filipino citizen
and a resident of BLK 1, LOT 2, Apple St., , Brgy. Sunshine, Quezon
City where they may be served with summons and other court
processes;

JURISDICTIONAL FACTS

4. This action for reconveyance involves a property situated in the

locality of Quezon City particularly in Blk 1, Lot 12, Brgy. Diliman,
Quezon City, with a value exceeding to Php 400,000, thus, under the
Rules of Court, it is within the jurisdiction of this Honorable Court;

ALLEGATIONS COMMON TO
ALL CAUSES OF ACTION

5. This is an action for recovery of property which involves a 225

square meter parcel of land (Lot 143143) situated in BLK 1, LOT 12,
Pinya Street, Brgy. Diliman, Quezon City with Transfer Certificate
of Title (TCT) No. 12345 (Annex “A”) which is originally and
lawfully owned by the plaintiff, Percival Chan covered by Tax
 Declaration No. 246810 with an assessed value of ONE MILLION
PESOS (Php1,000,000) (Annex “B”);

6. That on the said lot is situated the Ancestral Shrine of the Chan
Family, where heirlooms are secretly kept and maintained, with an
immeasurable sentimental value, which was entrusted to his land
caretaker, herein defendant, Eva Tan;

7. That herein defendant, Jose Dy, illegally purchased said lot from
Eva Tan on March 2, 2020 through a Falsified Notarized Special
Power of Attorney (SPA) (Annex “C”) as per the records of the
Absolute Deed of Sale (Annex “D”) with knowledge on the
illegalities employed by Eva Tan because he is a lawyer and he lives
in the same street and barangay as the plaintiff;

8. That said SPA is falsified because it shows that Atty. Elpidio T.

Siargao who notarized said SPA is already dead during the
purported notarization (Annex “K”);

9. That the additional documents claimed to be presented by Eva Tan

to Jose Dy which he demanded during before the sale was also a
Falsified Authorization Letter which forged Percy Chan’s
signature (Annex “E”);

10. That the sale of the land is unlawful and invalid, thus void ab
initio, because it was maliciously obtained by Eva Tan, through the
said Falsified Notarized SPA (Annex “C”) which is attested to by
Ali Chan-Rio (Annex “F”) and that Jose Dy bought in in bad faith,
with knowledge of the injustice and damage that will be acquired
by herein plaintiff;

11. That petitioner was at Hawaii, USA during the date of said sale
between Jose Dy and Eva Tan as attested by Dr. Mario Maurer
(Annex “G”) and the sale was impossible because:

1) He was living with his niece in Hawaii, USA from

February 2, 2018 up to January 18, 2023 as proven by his TRAVEL
HISTORY (Annex “H”), and was not physically present in the
Philippines to sign the notarized SPA;

2) He did not make nor authorize Eva Tan to sell his

property because it is an ancestral lot which he values the most
because it is an inheritance given by his family (Annex “L”), and
that he was confined in the US during the assailed sale (Annex
“G”).

12. On January 19, 2023, the plaintiff went home to the Philippines with
his niece and nephews and was excited to show them the heirlooms,
but to his dismay, said shrine was gone and his beloved land was
occupied;

13. That to their surprise, a law firm, ABC Law, owned by Jose Dy, was
put up on the said lot, to the damage and prejudice of the plaintiff;
14. That through the terrible news coming from his neighbors, he was
informed that Eva Tan announced sometime in 2020 that he already
passed away due to COVID in 2020 and ever since, the latter has
long vanished from Brgy. Diliman, and that his lot is already owned
by Jose Dy, a lawyer by profession;

15. That said news made his relatives from Hawaii look disappointed
through their stares and remarks: “What the fuck uncle!? Ang
tanga naman! Wala na pala tayong mababalikan sa Pinas! The
hell!” for having lost said ancestral property which had worsened
his health condition resulting in his hospitalization for one month at
St. Benedict Medical Center (Annex “I”);

16. Thus, on January 30, 2023, through herein counsel, the plaintiff
referred the matter to Iskolar Moreno (Capt. Isko), the Barangay
Captain of Brgy. Diliman;

17. After Capt. Penduko’s summons, only Jose Dy appeared at the

Conciliation Meeting and Eva Tan did not appear;

18. Unfortunately, after three baranggay conciliation meetings (Annex

“J”) wherein plaintiff stated his rightful ownership supported by
pieces of evidence and how he was abused of trust and confidence
by Eva Tan making the sale unlawful, and after asking the
defendant to return to him said lot because he is already old and
that he wants to leave the world leaving the entrusted ancestral lot
to his nieces and nephews as a part of their family tradition, the
defendant, Jose Dy, refused to settle and held out that he is now the
rightful owner of the averred lot; hence this complaint.

ALLEGATIONS IN SUPPORT OF THE PLAINTIFF’S

APPLICATION TO ANNUL ABSOLUTE DEED OF SALE,
CANCEL TRANSFER CERTIFICATE TITLE, RECONVEYANCE
AND DAMAGES

19. Art. 449 and Art. 450 of the New Civil Code provide:
Article 449. He who builds, plants or sows in bad faith on the
and of another, loses what is built, planted or sown without
right to indemnity. (362)1

Article 450. The owner of the land on which anything has

been built, planted or sown in bad faith may demand the demolition
of the work, or that the planting or sowing be removed, in order to
replace things in their former condition at the expense of the person
who built, planted or sowed; or he may compel the builder or planter
to pay the price of the land, and the sower the proper rent. (363a)2

20. Plaintiff repleads and adopts by way of reference all of the foregoing
allegations in so far as they are material hereto.

1
Article 449 of the New Civil Code of the Philippines
2
Article 450 of the New Civil Code of the Philippines
21. In Sps. Claro and Nida Bautista vs. Berlinda F. Silva, represented by
Hermes J. Dorado, G.R. No. 157434, 19 September 2006,3 the Court
ruled that a purchaser in good faith cannot rely merely on the face
of the title when one or two of the following conditions are not
present: (1) the seller is the registered owner of the parcel of land;
(2) the latter is in possession thereof; and (3) the buyer has no
knowledge as to any claim or interest of third persons in the
property, or of any restriction or defect in the title of the seller or
in the latter’s capacity to convey title to the property. The Court
further stated that in the absence of any of the above-said
conditions, a higher degree of diligence must have been exercised
by the buyer through scrutiny of the certificate of title and of all
other factual circumstances to determine the capacity of the seller to
dispose of the property. In fact, the Court further ruled:

“Under such circumstance, it is no longer sufficient

for said buyer to merely show that he relied on the
face of the title; he must now also show that he
exercised reasonable precaution by inquiring
beyond the title. Failure to exercise such degree of
precaution makes him a buyer in bad faith.”

xxx

“All told, it was not sufficient evidence of good faith

that petitioners merely relied on the photocopy of
the SPA as this turned out to be a mere private
document. They should have adduced more
evidence that they looked beyond it. They did not.
Instead, they took no precautions at all. They
verified with Atty. Lucero whether the SPA was
authentic but then the latter was not the notary
public who prepared the document. Worse, they
purposely failed to inquire who was the notary
public who prepared the SPA. Finally, petitioners
conducted the transaction in haste. It took them all
but three days or from March 2 to 4, 1988 to enter
into the deed of sale, notwithstanding the restriction
on the capacity to sell of Pedro. In no way then may
petitioners qualify as buyers for value in good
faith.”

22. In light of the foregoing, it is evident that in the purchase of the

subject property, Jose Dy cannot be upheld as a buyer in good faith
because all the requisites stated in Sps. Claro and Nida Bautista vs.
Berlinda F. Silva are present because:

3
G.R. No. 157434, 19 September 2006
 22.1.1. He personally knows that Eva Tan is not the registered
owner of the lot;
22.1.2. That Eva Tan is in possession thereof while he
personally knows that it is registered under Percy Chan;
22.1.3. That he has knowledge as to any claim or interest of
third persons in the property, or of any restriction or
defect in the title of the seller or in the latter’s capacity
to convey title to the property.

23. Jose Dy, being a lawyer and a neighbor of the plaintiff, had a
heightened duty of diligence to ensure the validity of the
transaction. His failure to exercise due diligence in verifying the
capacity of Eva Tan to sell the property renders him liable under
Articles 449 and 450 of the New Civil Code, as interpreted by
relevant jurisprudence;

24. Under Article 1456 of the Civil Code:

“[i]f property is acquired through mistake or fraud, the

person obtaining it is, by force of law, considered a trustee of
an implied trust for the benefit of the person from whom the
property comes.”4

25. The Court ruled in Gatmaytan v. Misibis Land, Inc.5 that the law thus
creates the obligation of the trustee to reconvey the property and
its title in favor of the true owner. An action for reconveyance of
property based on an implied constructive trust prescribes in ten
(10) years, in accordance with Article 1144(2) of the Civil Code,
which states that that an action involving an obligation created by
law must be brought within ten (10) years from the time the right of
action accrues.

26. Jose Dy, being a buyer in bad faith, should return the said property
to its rightful owner, Percy Chan, through the canceling of TCT
12345 and the annulment of Absolute Deed of Sale between her
and Eva Tan, reconveyance of TCT 12345 and to give moral and
exemplary damages that the Court would rightfully determine to
give the justice the plaintiff lawfully and rightfully deserves on the
basis of justice, equity and fair play.

27. Art. 1170 provides:

Those who in the performance of their obligation are guilty of fraud,
negligence, or delay, and those who in any manner contravene the tenor
thereof, are liable for damages.

4
Article 1456 of the New Civil Code of the Philippines
5
G.R. No. 222166, June 10, 2020
28. To take care of the averred property was an obligation that should
be fulfilled by Eva Tan. However, in the tenor of her fulfillment of
performance of the latter, she is guilty of fraud. Wherefore, the law
is clear on giving damages to Percy Chan for the fraud she has done.

29. As previously narrated, the plaintiff seeks to annul the Absolute

Deed of Sale Cancel the Transfer Certificate of Title, as well as the
reconveyance of the subject property to the plaintiff.

30. The facts of this case are clear and all the necessary requisites for
the issuance annulment of the Absolute Deed of Sale, cancel the
Transfer Certificate of Title, as well as the reconveyance of the
subject property to the plaintiff are present as per the requisites
provided in Sps. Claro and Nida Bautista vs. Berlinda F. Silva.6

31. Currently, the market value of the lot is continuously changing due
to its strategic location.

WITNESSES
I. ALI CHAN-RIO
1. That I am the NIECE of PERCIVAL CHAN;
2. That on February 2, 2018, my uncle has been living with me
until January 18, 2023 since his visit in Hawaii to attend my
wedding on March 10, 2018;
3. That the accused, Eva Tan of BLK 1, LOT 2, Apple St., , Brgy.
Sunshine, Quezon City, is known to me personally since she is
the trusted caretaker of my uncle’s lot now registered as TCT
12345;
4. That on January 19, 2023, with other relatives, we went home
to the Philippines together with my uncle, Percy Chan, where
we were informed by a neighbor that Eva Tan, sometime in
2020, spreaded the news that my uncle is already dead due to
COVID in 2020;
5. That after having been entrusted by the said lot of my uncle,
Percival Tan, Eva Tan took that opportunity to sell said land
using a falsified Notarized Special Power of Attorney (SPA)
to Jose Dy on March 2, 2020 by using a Falsified
Authorization Letter;
6. That she sold said property to Jose Dy, a famous lawyer in our
place and our neighbor as well since I was a child;
7. That said lot contained our Ancestral Shrine where heirlooms
of immeasurable sentimental quantity and value are kept;
8. That I executed this affidavit to attest the truthfulness of the
foregoing facts and to support the filing of a civil case against
Jose Dy and Eva Tan for the annulment of Deed of Sale,
cancellation of TCT 12345 and its reconveyance of the said lot
registered under TCT 12345 and not to harass, cause
unnecessary delay or increase the cost of litigation.
9. registered under TCT 12345 without an intention to cause

6
Ibid
32. In order to support his causes of action, the plaintiff hereby submits
the following documentary and object evidence marked herein as
Annexes A, B, C, E, F, G, H, I, J, K and L of this complaint.

List of Documentary Exhibits

RESERVATION

Plaintiff expressly reserves its right to present further

documentary evidence and other witnesses as may be warranted
during the course of the trial.

PRAYER

WHEREFORE, it is respectfully prayed unto this Honorable Court

that judgment be rendered:

1. CANCELING Transfer Certificate of Title No. 12345 in the

name of Jose Dy;

2. ANNULLING the Absolute Deed of Sale dated March 2, 2020

in favor of Jose Dy;

3. ORDERING the defendant to reconvey the subject parcel of

land to the plaintiff;

4. PAYING for damages incurred from the injury;

5. COSTS OF THIS SUIT be shouldered by the defendants and;

6. That other such remedies are consistent with law and equity
be granted.

Quezon City, Philippines, February 21, 2024

ATTY. JOHAN ANDRE B. ACUBA

Counsel for the Plaintiff
c/o SIRIOS AND ASSOCIATES LAW FIRM
#143 Paseo St., Alabang, Muntinlupa
IBP No. 452303/ 1-02-14/Muntilupa
PTR No. 7150933// 1-02-14/
Muntinlupa
Roll No. 3435
MCLE Compliance No. IV-
0079772/
Feb 14, 2017
Telephone No. (082) 714-2327
VERIFICATION AND CERTIFICATION
 OF NON-FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES )

QUEZON CITY ) S.S

I, Percival Chan, Filipino citizen, of legal age, and a resident of BLK

1, LOT 12, Pinya Street, Brgy. Diliman, Quezon City, after having been
duly sworn according to law, hereby depose and state that:

1. I am the plaintiff in the above-entitled case;

2. The facts stated in the above complaint are true and correct to
the best of my knowledge and authentic records;

3. This complaint is not filed to harass, cause unnecessary delay,

or needlessly increase the cost of litigation;

4. The factual allegations in the complaint have evidentiary

support, or if specifically so identified, will likewise have
evidentiary support after a reasonable opportunity for discovery;

5. I have not commenced any action filed any claim involving

the same issues in any court, tribunal, or quasi-judicial agency,
and to the best of my knowledge, no such other action or claim is
pending in them; and

6. If I should learn that the same or similar action or claim has

been filed or is pending after its filing, I shall report that fact
within five (5) days to the court or where the complaint or
initiatory pleading has been filed.

IN WITNESS WHEREOF, I have affixed my signature this 16th day of

February 2024 at Quezon City.

___________________
Percival Chan
Affiant
 JURAT

SUBSCRIBED and sworn to before me, this 16th day of February 2024, in
Quezon City by Percival Chan with Passport No. PH135790, issued on
January 3, 2018, at DFA NCR North, Novaliches, Quezon City.

ATTY. MIGUEL GERARD S. SIRIOS

Notary Public for Quezon City
Commission Serial No. 231
Until December 31, 2024
IBP No. 246810; 06/18/2001
PTR No. 1357924; 07/21/2001

Doc No. 28
Page No. 5
Book No. III
Series of 2024
 Annex “A”
Transfer Certificate of Title No. 12345
 ANNEX “B”
Tax Declaration No. 246810
 Annex “C”
SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

I, PERCIVAL CHAN, single, of legal age, with residence and postal

address at Block 1, Lot 12, Pinya Street, Barangay Diliman, Quezon
City, do hereby APPOINT EVA TAN, single, likewise of legal age, with
postal address at BLK 1, LOT 2, Apple St., Brgy. Sunshine, Quezon
City, as our true and legal representative to act for and in our name and
stead and to perform the following acts:

To sell, offer for sale, and come to an agreement as to the purchase price
and thereafter to sign for us and in our name and receive payment from
the sale of our property more particularly described as follows: Parcel
of land with Transfer Certificate of Title (TCT) No. 12345, with a lot
area of Two Hundred Twenty Five (225) square meters.

HEREBY GRANTING unto our representative full power and authority

to execute and perform every act necessary to render effective the
power to sell the foregoing property, as though we ourselves, have so
performed it, and HEREBY APPROVING ALL that he may do by virtue
hereof with full right of substitution of his person and revocation of this
instrument.

IN WITNESS WHEREOF, WE HAVE HEREUNTO SET OUR HANDS

THIS 1ST DAY OF FEBRUARY, 2018 at Peke St., Brgy. Diliman, Quezon
City.

PERCIVAL CHAN EVA TAN

Principal/Owner Attorney-in-Fact

Republic of the Philippines

S.S

BEFORE ME, personally appeared:

NAME CTC/ID Date/Place Issued

Number
PERCIVAL CHAN 34567890 February 1, 2018/
Quezon City
EVA TAN 0123456 February 1, 2018/
Quezon City
Known to me and to me known to be the same persons who executed
the foregoing instrument and acknowledge to me that the same is their
free and voluntary act and deed.

WITNESS MY HAND AND SEAL, on the date and place first above
written.

Atty. Elpidio T. Siargao

Notary Public

Doc. No. 1012;

Page No. 2;
Book No. 30;
Series of 2018.
 ANNEX “D”

ABSOLUTE DEED OF SALE

KNOW ALL MEN BY THESE PRESENTS:

This Deed of Sale is made and executed this March 2, 2020 by and
between:

EVA TAN, of legal age, Filipino, and a resident of BLK 1, LOT 2,

Apple St., Brgy. Sunshine, Quezon City, Philippines, hereinafter
referred to as the "SELLER";

and -

JOSE DY, of legal age, Filipino, and a resident of BLK 1, LOT 13,
Pinya Street, Brgy. Diliman, Quezon City, Philippines, hereinafter
referred to as the "BUYER";

WITNESSETH:

WHEREAS, the SELLER is the registered owner of a parcel of land located

in Quezon City, covered and described in Tax Declaration No. 246810;

WHEREAS, the SELLER seeks to transfer ownership of the said property

to the BUYER;

NOW, THEREFORE, for and in consideration of the sum of ONE

MILLION PESOS (Php1,000,000.00) paid by the BUYER to the SELLER,
the receipt and sufficiency of which are hereby acknowledged by the
SELLER, the parties hereto agree as follows:

1. The SELLER hereby sells, transfers, and conveys to the BUYER, his
heirs, successors, and assigns, the property covered by Tax
Declaration No. 246810 situated in Quezon City, Philippines,
together with all the improvements thereon, free from all liens and
encumbrances;

2. The BUYER acknowledges full knowledge and understanding of the

above-described property's condition, boundaries, and all other
pertinent details;

3. The BUYER agrees to assume all taxes, assessments, and expenses

relating to the property from the date of execution of this Deed of
Sale;

4. The BUYER agrees to indemnify and hold the SELLER harmless

from any claims, demands, or liabilities arising from the BUYER's
ownership and possession of the property;

5. This Deed of Sale shall be binding upon the parties, their heirs,
successors, and assigns;
IN WITNESS WHEREOF, the parties hereto have hereunto set their
hands on the day and year first above written in Quezon City, Philippines.

SELLER BUYER

Eva Tan Jose Dy

WITNESS WITNESS

Leroyn Carasco Celine Deeon

 ANNEX “E”
Republic of the Philippines
Philippine Embassy in Hawaii, USA

AUTHORIZATION TO SELL

KNOW ALL MEN BY THESE PRESENTS:

That EVA TAN of legal age , Filipino and a resident of

BLK 1, LOT 2, Apple St., , Brgy. Sunshine, Quezon City, entered into an
agreement with the Land Owner, Percival Chan is hereby given an
authorization to sell and transact our land property with the following
details;

Lot No. 143143

Tax Dec. No. : 246810

LOCATION: BLK 1, LOT 12, Pinya Street, Brgy. Diliman, Quezon City;

LOT AREA in SQM: 225 SQM

IMPROVEMENTS: With Ancestral Shrine

Should the sale be made or effected to EVA TAN , I, PERCIVAL

CHAN, the owner will only receive the amount of FIVE HUNDRED
THOUSAND Pesos Only (Php 500,000 ).

That all expenses related to this sale will be shouldered on whatever gains
received beyond the fixed price agreed to both parties.

IN WITNESS WHEREOF, the parties have hereunto affixed their

signatures, this

20th day of January, 20 18 at ____HONOLULU __, USA.

OWNER/ SELLER:

PERCIVAL CHAN

CONFORME:

______________________________

WITNESSED:

MARIA MONTEREAL ALI CHAN-RIO

Consul, Philippine Embassy-Hawaii Witness of the Owner/Seller

 ANNEX “F”
Republic of the Philippines
Quezon City ) S.S
National Capital Region

AFFIDAVIT OF UNDERTAKING

I, ALI CHAN-RIO, of legal age, Filipino, married and a resident of

1457 Lilo Court, Hawaii, USA, after having been duly sworn to in
accordance with law, depose and state:

1.That I am the NIECE of PERCIVAL CHAN;

2. That on February 2, 2018, my uncle has been living with me until

January 18, 2023 since his visit in Hawaii to attend my wedding;

3. That the accused, Eva Tan of BLK 1, LOT 2, Apple St., , Brgy.
Sunshine, Quezon City, is known to me personally since she is the
trusted caretaker of my uncle’s lot now registered as TCT 12345;

4. That on January 19, 2023, with other relatives, we went home to

the Philippines together with my uncle, Percy Chan, where we were
informed by a neighbor that Eva Tan, sometime in 2020, spreaded
the news that my uncle is already dead due to COVID in 2020;

5. That after having been entrusted by the said lot of my uncle,

Percival Tan, Eva Tan took that opportunity to sell said land using a
falsified Notarized Special Power of Attorney (SPA) to Jose Dy on
March 2, 2020 by using a Falsified Authorization Letter to obtain
said SPA;

6. That she sold said property to Jose Dy, a famous lawyer in our
place and our neighbor as well whonis known to me personally;

7. That said lot contained our Ancestral Shrine where heirlooms of

immeasurable sentimental quantity and value are kept;

8. That I executed this affidavit to attest the truthfulness of the

foregoing facts and to support the filing of a civil case against Jose
Dy and Eva Tan for the annulment of Deed of Sale, cancellation of
TCT 12345 and its reconveyance of the said lot registered under TCT
12345 and not to harass, cause unnecessary delay or increase the
cost of litigation.

IN WITNESS WHEREOF, I hereby affixed my signature this 3rd day of

January 2024 in Quezon, City, Philippines.

_________Ali Chan-Rio______

Affiant
 SUBSCRIBED AND SWORN TO before me this 3rd day of January, 2024
in Quezon, City, Philippines, affiant exhibiting to me his/her competent
evidence of identity by way of _Permanent Residency Card__with ID
Number USCIS# 563-928-005 issued at Quezon, City on January 3, 2024.

Doc. No. 1;
Page No.2;
Book No. 123;
Series of 2024

ATTY. MIGUEL GERARD S. SIRIOS

Notary Public for Quezon City
Commission Serial No. 231
Until December 31, 2024
IBP No. 246810; 06/18/2001
PTR No. 1357924; 07/21/2001
ANNEX “G”
 ANNEX “H”

TRAVEL HISTORY
 Annex “I”

ST. BENEDICT MEDICAL CENTER

CERTIFICATE OF CONFINEMENT

Date: February 20, 2023

TO WHOM IT MAY CONCERN:

THIS IS TO CERTIFY that PERCIVAL CHAN, 86 years old,

MALE from BLK 1, LOT 12, Pinya St., Brgy. Diliman, Quezon City was
examined and confined in this hospital on / from January 19, 2023 to
February 19, 2023 under the service of Dr. Romeo Sabotaje with the
following admitting diagnosis:

HYPERTENSION AND MYOCARDIAL INFARCTION

This certification is being issued upon request of Mr. Chan for

whatever purpose it may serve them.

Dr. Romeo Sabotaje

Attending Physician

PRC License No.: 123456789

PTR No.: 12345

Annex “J”
 Annex “K”
DEATH CERTIFICATE OF ATTY. SIARGAO
Annex “L”