Create a Notes file
Open a Bible and right-click somewhere in it
Select Add note to "Newly Created Notes File"
Select the title text of the note that just got created by clicking in it and pressing Ctrl+A
Hit Delete.
The title was deleted, but there is no way you can get out of that field without the old text popping back in when you leave it. Press Tab, or click in another tile.
The only way to make it look like you've deleted the title appears to be to replace that text with a space character. That change sticks if the Title field loses the focus. But if you totally delete the title, not so.