Buying inherited land in the Philippines is already a transaction that requires heightened caution. When the title carries an annotation of adverse claim, the risks become significantly more serious. The annotation is a formal warning on the title that another person is asserting a legal or equitable interest over the property. It does not automatically mean the adverse claimant owns the land, but it does mean the buyer is being placed on notice that the title is disputed.

In Philippine real property transactions, a buyer who proceeds despite an adverse claim annotation may lose the protection ordinarily given to an innocent purchaser for value. The annotation can affect ownership, possession, registration, financing, resale, and litigation exposure.

This article explains the nature of adverse claims, why they are especially risky in inherited land transactions, what legal consequences may arise, and what due diligence should be done before buying.

1. Meaning of an Adverse Claim

An adverse claim is a written claim registered with the Registry of Deeds by a person who asserts an interest in registered land that is adverse to the registered owner or to another claimant.

It is commonly annotated on the Transfer Certificate of Title or Original Certificate of Title.

The purpose is to give notice to the public that someone other than the registered owner claims a right over the property. The claim may arise from ownership, sale, inheritance, possession, mortgage, lease, trust, donation, or another legal basis.

In simple terms, an adverse claim annotation says:

“A person is formally claiming an interest in this land, and anyone dealing with the property should beware.”

It is not conclusive proof that the claimant is correct. It is, however, a serious red flag.

2. Legal Effect of an Adverse Claim Annotation

An adverse claim does not automatically cancel the owner’s title. It does not by itself transfer ownership. It does not always prevent the owner from selling the land.

However, it has strong legal consequences:

First, it gives constructive notice to the whole world. Anyone who inspects the title is deemed to know that the property is subject to a dispute.

Second, it weakens or defeats a buyer’s claim of being an innocent purchaser for value. A buyer cannot easily say they bought in good faith when the title itself warned them of an adverse claim.

Third, it may expose the buyer to litigation. The adverse claimant may sue to annul the sale, recover ownership, enforce a prior sale, demand reconveyance, or protect hereditary rights.

Fourth, it may affect the buyer’s ability to register a clean title. Even if the sale is registered, the adverse claim may remain annotated unless cancelled through proper procedure.

Fifth, it may affect marketability. Banks, buyers, and developers usually avoid land with adverse annotations unless the issue is resolved.

3. Why the Risk Is Greater When the Land Is Inherited

Inherited land presents special risks because ownership may not be fully settled. In Philippine practice, many inherited properties remain titled in the name of a deceased person for years or decades. Family members may occupy, sell, mortgage, lease, or divide property informally without completing estate settlement.

When an adverse claim appears on inherited land, it often signals deeper estate-related issues.

Common problems include:

A. Not All Heirs Joined the Sale

A person selling inherited land may claim to be the owner but may only be one of several heirs. Under succession law, heirs acquire rights upon the death of the decedent, but the estate may still need settlement, partition, and tax compliance.

If one heir sells the entire property without authority from the other heirs, the sale may be valid only as to that heir’s undivided share, not the entire land.

A buyer who purchases from only some heirs may later face claims from excluded heirs.

B. There May Be Compulsory Heirs

The seller may say the property belongs to them, but Philippine succession law protects compulsory heirs such as legitimate children, surviving spouse, illegitimate children, and, in some cases, parents or ascendants.

A sale that prejudices the legitime of compulsory heirs may later be challenged.

C. There May Be a Prior Extrajudicial Settlement

The heirs may have executed an extrajudicial settlement, but another heir or claimant may contest it. The adverse claim may have been filed by someone alleging exclusion, fraud, forgery, lack of notice, or improper partition.

D. There May Be an Unsettled Estate

If the estate has not been settled, no individual heir may have a specific exclusive portion unless there has been a valid partition. Each heir may own an ideal or undivided share, not a definite lot area.

Buying a specific portion from one heir without partition can create serious boundary and ownership problems.

E. There May Be Family Possession Issues

One heir may be in possession and appear to be the owner, but possession alone does not necessarily prove exclusive ownership. Other heirs may still have hereditary rights.

F. There May Be Tax and Registration Issues

Estate tax, donor’s tax, capital gains tax, documentary stamp tax, transfer tax, and real property tax issues may delay or prevent registration. A buyer may pay the purchase price but later discover that the title cannot be transferred cleanly.

4. Common Reasons an Adverse Claim Is Annotated on Inherited Land

An adverse claim annotation may arise from many circumstances. In inherited land transactions, the most common are the following:

A. Claim by an Excluded Heir

An heir may file an adverse claim because they were omitted from an extrajudicial settlement, deed of sale, deed of partition, or transfer.

Example: A land title is transferred to three siblings after their father’s death. A fourth sibling later claims they were excluded and annotates an adverse claim.

B. Claim by a Buyer Under a Prior Sale

The deceased owner or one of the heirs may have previously sold the property to another person. If that buyer failed to register the deed immediately, they may later file an adverse claim to protect their interest.

Example: The father sold the land before death, but the title was never transferred. After death, the heirs sell the same land to someone else. The first buyer annotates an adverse claim.

C. Claim by a Co-Heir Who Opposes Sale

One heir may oppose the sale made by another heir or by an administrator. The adverse claim may be used to warn buyers that the seller has no authority to dispose of the whole property.

D. Claim Based on Forgery

A claimant may allege that a deed of sale, waiver of rights, settlement, or special power of attorney was forged.

Forgery is a serious issue because a forged deed generally conveys no title.

E. Claim by a Possessor or Occupant

A long-time possessor may claim ownership by sale, donation, inheritance, or other right. They may use adverse claim annotation to protect their asserted interest.

F. Claim by a Creditor

A creditor of the deceased or of the heirs may claim an interest affecting the property. Estate debts can complicate distribution and sale.

G. Claim by a Spouse

A surviving spouse or spouse of an heir may claim conjugal, community, or hereditary rights. In some cases, property believed to be inherited may be mixed with marital property claims.

H. Claim Based on Trust or Agency

A person may claim that the registered owner holds the property in trust or that a sale was made through an agent.

I. Claim Involving Informal Family Agreements

Many Filipino families divide inherited land orally or informally. A later formal sale may conflict with these arrangements, causing an adverse claim.

5. Is Land With an Adverse Claim Annotation Still Saleable?

Technically, yes, land with an adverse claim may still be sold unless there is a court order, notice of lis pendens, levy, attachment, injunction, or other restriction preventing sale.

But practically and legally, buying it is risky.

The seller may still execute a deed of sale, and the buyer may attempt registration. However, the buyer takes the property subject to the annotated claim. The adverse claimant may later challenge the transaction.

A buyer cannot simply ignore the annotation. The annotation is part of the title. It is a direct warning.

6. The Doctrine of Innocent Purchaser for Value

A major issue in these transactions is whether the buyer can be considered an innocent purchaser for value.

An innocent purchaser for value is someone who buys property:

for valuable consideration;
from a person who appears to have valid title;
without notice of any defect, claim, or adverse interest; and
in good faith.

An adverse claim annotation makes good faith difficult to prove. Since the annotation appears on the title, the buyer is deemed to have notice. The buyer cannot usually say:

“I did not know there was another claimant.”

The law expects buyers of registered land to inspect the title and respect its annotations.

Thus, if the buyer proceeds despite an adverse claim, they may be considered a buyer in bad faith or at least a buyer with notice of a potential defect.

7. Risks to the Buyer

A. Risk of Losing the Property

The greatest risk is that the adverse claimant may later prove a superior right. If that happens, the buyer may lose all or part of the property.

For example, if the adverse claimant proves they are an excluded compulsory heir, the buyer’s ownership may be reduced or invalidated to the extent that the sale prejudiced that heir’s rights.

If the claimant proves a prior valid sale, the later buyer may lose the property.

If the claimant proves forgery, the sale may be void.

B. Risk of Buying Only an Undivided Share

If the seller is only one heir, the buyer may acquire only that heir’s undivided hereditary share. The buyer does not automatically acquire the entire lot or a specific physical portion unless all co-owners agree or partition is completed.

This means the buyer may become a co-owner with the other heirs, which can be difficult and contentious.

C. Risk of Litigation

The buyer may be dragged into civil cases such as:

annulment of sale;
reconveyance;
partition;
quieting of title;
cancellation of title;
recovery of possession;
damages;
injunction;
specific performance;
settlement of estate;
declaration of nullity of documents.

Litigation can take years and may cost more than the property’s expected gain.

D. Risk of Delayed Transfer of Title

The Registry of Deeds may not necessarily refuse registration solely because of an adverse claim, but the annotation can complicate registration. Other requirements may also arise, especially if the property is inherited.

The buyer may face problems securing:

electronic Certificate Authorizing Registration from the BIR;
estate tax clearance;
transfer tax clearance;
tax declaration transfer;
cancellation of annotations;
subdivision approval;
partition documents;
court orders.

E. Risk of Bank Financing Being Denied

Banks generally require clean, marketable title. A title with an adverse claim is often unacceptable as collateral unless the claim is cancelled or fully resolved.

A buyer relying on financing may lose reservation payments, deposits, or incur penalties if the bank refuses the title.

F. Risk of Resale Problems

Even if the buyer accepts the risk, future buyers may not. A property with an adverse claim annotation is harder to sell, lease, develop, or mortgage.

The buyer may later be forced to sell at a discount.

G. Risk of Possession Disputes

The buyer may acquire paper title but not actual possession. The adverse claimant or other heirs may occupy the land.

Ejectment, accion publiciana, accion reivindicatoria, and other possession cases may follow.

H. Risk of Paying for a Property That Cannot Be Delivered

The seller may promise to “fix the annotation later.” If the seller fails, the buyer may have paid money for a defective transaction.

Recovery of the purchase price may require another lawsuit, especially if the seller has already spent the money.

I. Risk of Hidden Heirs

Inherited land often involves undisclosed heirs, especially in families with children from different relationships, illegitimate children, prior marriages, adopted children, or heirs living abroad.

A buyer should not rely solely on the seller’s statement that “we are the only heirs.”

J. Risk of Fraudulent Documents

Documents commonly used in inherited land sales may be forged or defective, including:

death certificates;
birth certificates;
marriage certificates;
extrajudicial settlement documents;
waivers of rights;
special powers of attorney;
deeds of sale;
affidavits of self-adjudication;
tax declarations;
certificates of no improvement;
subdivision plans;
identification cards.

A forged notarized document can appear regular on its face but still be legally void.

8. Adverse Claim vs. Notice of Lis Pendens

An adverse claim is different from a notice of lis pendens.

A notice of lis pendens means there is a pending court case involving the property or title. It directly warns that the land is under litigation.

An adverse claim may exist even before a court case is filed. It is a registered claim of interest by another person.

Both are serious. If a title has both an adverse claim and a lis pendens annotation, the risk is even greater.

A buyer should treat either annotation as a major warning.

9. Adverse Claim vs. Encumbrance

An adverse claim is a type of annotation or encumbrance, but not all encumbrances are adverse claims.

Other common annotations include:

mortgage;
lease;
easement;
lien;
levy;
attachment;
notice of lis pendens;
restriction;
right of way;
court order;
adverse claim;
deed of sale;
extrajudicial settlement;
affidavit of loss;
notice of tax lien.

Each annotation must be separately examined. A title may have several defects, not just one.

10. Does an Adverse Claim Expire?

Under Philippine land registration rules, adverse claims are generally subject to a statutory period, but in practice, annotations may remain on title until properly cancelled.

A buyer should not assume that an old adverse claim is harmless merely because many years have passed. The annotation may still appear on the title, and registries, banks, courts, and future buyers may treat it as unresolved.

Cancellation usually requires compliance with legal procedure, which may involve notice, hearing, agreement of the claimant, or court action.

The safer rule is:

If it is still annotated, treat it as legally significant.

11. Can the Seller Cancel the Adverse Claim Before Sale?

Sometimes, yes.

The seller may seek cancellation if:

the claimant voluntarily withdraws the claim;
the claim has no legal basis;
the required period has lapsed and cancellation is proper;
a court orders cancellation;
the issue has been settled by compromise;
the claimant’s interest has been satisfied;
the annotation was improper.

However, cancellation is not always simple. The Registry of Deeds may require documents, notice to the adverse claimant, or a court order. If the adverse claimant contests cancellation, the issue may need litigation.

A buyer should generally require the seller to cancel the adverse claim before full payment.

12. Buying Before Cancellation: Why It Is Dangerous

Some sellers offer a lower price and tell the buyer:

“You can buy now. The adverse claim is just a formality.”

This is dangerous.

The buyer may be tempted by a discounted price, but the discount may not compensate for the legal risk.

Buying before cancellation means the buyer knowingly steps into the dispute. The adverse claimant may argue that the buyer acted in bad faith. Courts may be less sympathetic to a buyer who purchased despite the warning on the title.

The buyer may also inherit the burden of resolving the issue.

13. Special Problems in Sales by Heirs

A. Sale Before Settlement of Estate

Heirs may sell their hereditary rights, but selling a specific property before estate settlement can be problematic if the estate has debts, other heirs, or no partition.

A buyer should distinguish between:

sale of hereditary rights;
sale of undivided share;
sale of a specific parcel;
sale by all heirs after partition;
sale by an estate administrator;
sale under court authority.

These are not the same.

B. Sale by One Heir of the Entire Property

One heir cannot generally sell what belongs to all heirs. The buyer may acquire only the seller-heir’s share.

C. Sale by Attorney-in-Fact

If an heir is represented by an attorney-in-fact, the special power of attorney must be carefully reviewed. It should clearly authorize sale, identify the property, and be properly executed.

If the heir is abroad, consular acknowledgment or apostille-related formalities may be relevant.

D. Sale by Administrator or Executor

If the estate is under judicial settlement, the administrator or executor may need court authority to sell estate property. A buyer must inspect the court order.

E. Extrajudicial Settlement With Sale

A common document is an “Extrajudicial Settlement of Estate With Deed of Sale.” This can be valid if all heirs participate and legal requirements are satisfied. However, it may be challenged by omitted heirs, creditors, or persons claiming prior rights.

F. Self-Adjudication

An affidavit of self-adjudication is proper only when there is a sole heir. If there are other heirs, it may be defective or fraudulent.

14. Due Diligence Before Buying

A buyer should not rely on the seller, broker, or photocopy of title alone.

The following checks are important:

A. Obtain a Certified True Copy of the Title

Secure a fresh certified true copy from the Registry of Deeds or authorized source. Examine all annotations, not just the front page.

Check:

title number;
registered owner;
technical description;
area;
encumbrances;
adverse claims;
mortgages;
liens;
court cases;
restrictions;
prior transactions.

B. Read the Exact Adverse Claim Annotation

The annotation usually includes information such as:

name of claimant;
date of annotation;
basis of claim;
document number;
entry number;
affected property;
sometimes a brief description of the claim.

The exact wording matters.

A vague annotation still matters. A detailed annotation may reveal a serious defect.

C. Request the Adverse Claim Documents

Ask for certified copies of the adverse claim affidavit and supporting documents from the Registry of Deeds.

Do not rely on the seller’s explanation.

D. Identify the Claimant

Find out who filed the adverse claim:

heir;
buyer;
spouse;
creditor;
possessor;
co-owner;
corporation;
government agency;
neighbor;
developer;
mortgagee.

The identity of the claimant helps determine the risk.

E. Determine Whether There Is a Pending Case

Search court records if possible. Ask the seller and claimant directly. A notice of lis pendens may indicate litigation, but the absence of lis pendens does not guarantee there is no case.

F. Verify the Death and Heirship Facts

For inherited land, verify:

death certificate of the registered owner;
marriage certificate;
birth certificates of heirs;
legitimacy or filiation issues;
surviving spouse;
children from prior relationships;
illegitimate children;
adopted children;
prior estate proceedings;
wills;
settlement documents.

G. Check Estate Tax Compliance

Estate tax issues can prevent or delay title transfer. Ask for proof of estate tax settlement or applicable clearance.

H. Check Real Property Taxes

Secure latest tax declaration, real property tax clearance, and assessment records.

I. Inspect Possession

Visit the property. Ask:

Who occupies it?
Are there tenants?
Are there informal settlers?
Are there relatives in possession?
Are there boundary conflicts?
Are there crops, structures, fences, or improvements?
Does possession match the seller’s story?

Actual possession by someone other than the seller is a warning sign.

J. Talk to the Adverse Claimant

This may be uncomfortable but is often necessary. The buyer should understand the claimant’s position before paying.

The claimant may show documents that the seller did not disclose.

K. Require a Written Legal Opinion

For significant transactions, a lawyer should review the title, adverse claim, estate documents, tax documents, and seller authority.

L. Verify the Seller’s Capacity and Authority

Confirm that sellers are the actual heirs or authorized representatives. Require valid identification and proper notarization.

M. Check the Approved Survey and Boundaries

Inherited lands often have subdivision or partition issues. Make sure the land being sold matches the title, tax declaration, survey plan, and actual ground location.

15. Contractual Protections for the Buyer

If a buyer still considers purchasing, the contract should contain strong protections.

A. Condition Precedent

The sale should be conditioned on cancellation of the adverse claim before full payment.

Example:

The obligation of the buyer to pay the balance shall arise only after the adverse claim annotated on the title has been fully cancelled at the seller’s sole expense.

B. Escrow Arrangement

Instead of paying the seller directly, funds may be placed in escrow and released only after title is cleared.

C. Holdback

Part of the purchase price may be withheld until the annotation is cancelled and the title transferred.

D. Seller’s Warranty

The seller should warrant that they have full ownership and authority to sell, and that no other heirs, claimants, tenants, or possessors have superior rights.

E. Indemnity Clause

The seller should indemnify the buyer for claims, litigation, damages, taxes, penalties, attorney’s fees, and loss arising from the adverse claim or estate defects.

F. Rescission Clause

The buyer should have the right to cancel the transaction and recover payments if the adverse claim is not cancelled by a specific date.

G. Direct Settlement With Claimant

If the claimant has a legitimate but settleable claim, the agreement should include the claimant as a party. A side agreement not reflected in the deed may be insufficient.

H. No Full Payment Until Clean Title

This is one of the most important protections. Full payment before cancellation exposes the buyer to the seller’s non-performance.

16. Red Flags That Should Stop the Transaction

A buyer should be extremely cautious or walk away if any of the following appear:

the seller refuses to provide a certified true copy of title;
the seller says the adverse claim is “nothing” but cannot prove it;
the seller wants full payment before cancellation;
the claimant is an heir excluded from settlement;
there is a pending court case;
the land is still titled in the name of a deceased person;
only one heir is selling;
some heirs are abroad and represented by questionable documents;
the deed involves a waiver of rights with unclear consideration;
the title has multiple annotations;
the property is occupied by someone other than the seller;
there are boundary disputes;
the seller offers a large discount for quick payment;
the documents are old, incomplete, or inconsistent;
the claimant alleges forgery;
the seller pressures the buyer to rely on trust.

17. Remedies of the Adverse Claimant

The adverse claimant may pursue various remedies, depending on the basis of the claim.

These may include:

A. Action for Reconveyance

If the claimant alleges that title was wrongfully transferred, they may seek reconveyance.

B. Annulment or Nullification of Sale

If the sale was unauthorized, fraudulent, or based on forged documents, the claimant may seek annulment or declaration of nullity.

C. Partition

If the claimant is a co-heir or co-owner, they may seek partition of the property.

D. Quieting of Title

If there are conflicting claims, a party may seek judicial determination of rights.

E. Recovery of Possession

If the buyer takes possession, the claimant may sue to recover possession.

F. Damages

The claimant may seek damages against sellers, buyers, brokers, notaries, or other parties if bad faith, fraud, or unlawful dispossession is involved.

G. Criminal Complaint

In cases involving falsification, fraud, forged documents, or estafa, criminal complaints may arise.

18. Remedies of the Buyer

If the buyer already purchased land with an adverse claim and later encounters problems, possible remedies include:

A. Demand Cancellation or Compliance From Seller

If the contract required the seller to clear the title, the buyer may demand performance.

B. Rescission

If the seller fails to deliver clean title or misrepresented ownership, the buyer may seek rescission and refund.

C. Damages

The buyer may claim damages, attorney’s fees, costs, and other losses if the seller acted in bad faith or breached warranties.

D. Intervention in Pending Case

If litigation affects the property, the buyer may need to intervene or defend their interest.

E. Settlement With Claimant

In some cases, settlement may be cheaper than litigation. However, settlement should be carefully documented and registered when appropriate.

F. Action to Cancel Adverse Claim

If the claim is baseless, the buyer or registered owner may seek cancellation through proper legal procedure.

G. Partition or Co-Ownership Remedies

If the buyer acquired only an undivided share, they may seek partition or sale of the co-owned property, subject to legal rules.

19. Broker and Notary Issues

A buyer should not rely solely on brokers. Brokers may facilitate the sale but may not fully investigate legal title.

A notarized deed is not a guarantee of ownership. Notarization converts a private document into a public document, but it does not cure lack of ownership, forgery, absence of authority, or violation of hereditary rights.

A clean-looking deed cannot defeat a serious title defect.

20. Practical Scenarios

Scenario 1: One Heir Sells the Entire Land

The title is in the deceased father’s name. One child sells the land and says the siblings agree. An adverse claim is annotated by another sibling.

Risk: The buyer may acquire only the selling heir’s share, not the entire property.

Scenario 2: Prior Buyer Files Adverse Claim

The deceased owner sold the land years ago, but the buyer did not transfer the title. After the owner dies, the heirs sell the land again. The first buyer annotates an adverse claim.

Risk: The later buyer may lose to the first buyer, especially if the first sale is proven valid and the later buyer had notice.

Scenario 3: Excluded Illegitimate Child

The legitimate children execute an extrajudicial settlement and sell the land. An illegitimate child files an adverse claim.

Risk: The sale may be challenged to protect the omitted heir’s hereditary share.

Scenario 4: Forged Waiver

Some heirs supposedly waived their rights, but one heir claims the waiver was forged and annotates an adverse claim.

Risk: If forgery is proven, the waiver may be void and the buyer’s title may be affected.

Scenario 5: Adverse Claim Is Old

The adverse claim was annotated many years ago. The seller says it has expired.

Risk: If it remains on the title, it still affects marketability and may require formal cancellation.

21. Key Legal Principles

The following principles are central:

A. A Buyer Must Examine the Title

A buyer of registered land must inspect the certificate of title and its annotations. Annotations are not decorative; they are legal warnings.

B. Notice Defeats Good Faith

A buyer who knows, or is deemed to know, of an adverse claim cannot easily invoke good faith.

C. Heirs Cannot Sell More Than They Own

An heir cannot transfer more rights than they have. A seller who owns only an undivided share cannot sell the whole property as sole owner.

D. Forgery Transfers No Valid Title

A forged deed is generally void and cannot convey ownership, even if later transactions occur.

E. Registration Does Not Cure a Void Sale

Registration protects valid transactions. It does not make a void document valid.

F. Possession by Another Person Requires Inquiry

If someone other than the seller occupies the land, the buyer must investigate their rights.

G. Inherited Property Requires Heirship Verification

The buyer must know who the heirs are, whether the estate has been settled, and whether all necessary parties consented.

22. Recommended Buyer Approach

The safest approach is:

Do not pay the full purchase price while the adverse claim remains.
Obtain a certified true copy of the title.
Secure the adverse claim documents from the Registry of Deeds.
Identify and communicate with the adverse claimant.
Verify all heirs and estate documents.
Require cancellation of the adverse claim before closing.
Use escrow or conditional payment.
Require all heirs and spouses, where legally necessary, to sign.
Verify tax compliance and possession.
Have counsel review the transaction before signing.

23. Should You Buy Inherited Land With an Adverse Claim?

As a legal and practical matter, this kind of purchase is high risk.

It may be acceptable only when:

the adverse claim is clearly baseless;
the claimant has agreed to withdraw it;
the claim can be cancelled before full payment;
all heirs are identified and properly represented;
estate taxes and transfer documents are ready;
there is no pending litigation;
possession is peaceful;
the buyer’s lawyer has reviewed the documents;
the price reflects the risk;
payment is protected by escrow or holdback.

It is dangerous when:

the claimant is an omitted heir;
the seller cannot explain the annotation;
the title remains in the deceased owner’s name;
not all heirs are participating;
there are possession disputes;
the seller demands full payment first;
court proceedings are pending;
forgery is alleged;
the buyer needs bank financing;
the buyer plans immediate development or resale.

24. Conclusion

An adverse claim annotation on inherited land is not a minor technical issue. It is a formal notice that someone is asserting a competing right over the property. In the Philippine setting, where inherited lands are often affected by incomplete estate settlement, missing heirs, informal family arrangements, tax issues, and delayed registration, an adverse claim can signal serious defects.

The main risk is that the buyer may not receive full, peaceful, and marketable ownership. The buyer may acquire only an undivided share, inherit litigation, face cancellation or reconveyance claims, lose financing, or be unable to resell the property.

The safest legal position is to require the adverse claim to be resolved and cancelled before full payment and transfer. A buyer who proceeds despite the annotation should do so only with full awareness that they are buying into a dispute, not merely buying land.