Republic of the Philippines)Province of Sorsogon)S.SSorsogon City )

AFFIDAVITI, SALVACION G. GALAN, of legal age, Filipino, married and residing at Brgy.Macabari, Barcelona, Sorsogon, Philippines, after having sworn in accordance with law, do hereby state:1. That I am the plaintiff in the above-captioned case and one of the legitimate heirs of the Late Maria Ganace(deceased), owner of a parcel of agricultural land designated as Lot 003, bounded on the North by Lot 1356, on the South by Lot 2527, on the East by Lot 2452, and on the West by Lot 2456;

2. That sometime in 1972, the grandfather of defendants LEANDRO PURA and LEONARDO PURA, was constituted as farm worker of said property by Cornelio Gaurano(deceased), father of the plaintiff, with the condition that the land shall revert to the latter upon his arrival from Mindanao;;

3. That in 1976, Maria Ganace (deceased), my mother, went home from Mindanao and mortgaged the property to Manuel Gaurano, brother of the plaintiff;

4. That by virtue of such mortgage, THELMA BACLAO, niece of the wife of Manuel Gaurano, was constituted as administratrix of the property because of a special power of attorney issued in her favor by Manuel Gaurano;

5. That in 1978, Magdalena Gaurano redeemed the property from Manuel Gaurano; hence, ownership and possession was devolved again in favor of Maria Ganace(deceased).Meanwhile Manuel Gaurano constituted Reynaldo Gaurano, brother of the plaintiff as administrator;

6. That upon his assumption, the said brother of the plaintiff employed Domingo Pura(deceased) as farm workers. Upon his death he was succeeded by his sons, namely, LEANDRO PURA and LEONARDO PURA;

7. That the special power of attorney issued in favor of THELMA BACLAO was terminated upon the death of Manuel Gaurano, her principal, as provided under paragraph 3, Article 1919 of the New Civil Code;

8. That since their employment as farm workers they have not been paying the rentals due upon them to the prejudice of the heirs of MARIA GANACE, my mother;

9. That I exhausted all remedies before the BARC but the respondents failed to appear on the mediation hearings on the said office;

10. That the land measures only ____ square meters which is too small accommodate tenants like the herein respondents. On the contrary, the legitimate heirs of Maria Ganace had been deprived of agricultural lands to cultivate and utilize as source of livelihood;

11. That the respondents can hardly be considered tenants within the purview of the law, considering the absence of the requisites of tenancy.

IN WITNESS WHEREOF, affiant hereby affixed his signature this __________ day of May 2015 at, Sorsogon City, Philippines.

SUBSCIRBED and SWORN to before me this__________ day of May 2015, affiant known to me, showing his ID NO.____________________ at Sorsogon City, Philippines.

NOTARY PUBLIC