You are on page 1of 3

PATHEADS LAW OFFICE

#101 Upper Bonifacio Rd., Baguio City


patheads2019@gmail.com
Tel. No. (123) 4567-890

8 March 2018
Ms. Maria Cristina Briones
Chairman
Pitak Realty Inc.
K’s Loft, #85 T. Alonzo St.
Baguio City, Philippines

Dear Ms. Briones,

In reference to Board Resolution No. 12-31-01 of Pitak


Realty Inc. (PRI), you are hereby demanded to fulfil your
obligations to Pedro Batongbuhay, former director of your
corporation. As payment for Batongbuhay’s unpaid salaries
amounting to P12,000,000.00 your corporation has
promised to satisfy said debt through the transfer of certain
properties.

As espoused in the Board Resolution, the following are


the properties in question:
1. 1 Corporate share of “A” Club SPA
2. Unit 1, Lipat Bahay Condominium
3. Unit 2, Lipat Bahay Condominium
4. Unit 3, Lipat Bahay Condominium
5. Unit 4, Lipat Bahay Condominium
6. 7 hectare agricultural land covered by OCT No. 03

From the listed properties only the following were


delivered to our client:
1. 1 corporate share of “A” Club Spa, but still in the name of
PRI
2. Title to units 1 and 2 of Lipat Bahay Condominium still
in the name of PRI
3. Owner’s copy of OCT No. 03 still in the name of Daga
4. Notarized deed of Sale dated January 12, 1997 executed
by Daga in favor of PRI regarding the said agricultural
land.

In order to fully satisfy the debt and consolidate


ownership, as held by our laws, Pedro Batongbuhay, now
called Peter Livingstone formally demands the following in
lieu of the said unpaid debt and the issued Board Resolution:

1. That one corporate share of “A” Club SP (amounting to


P1,000,000.00) be properly recorded and registered in
the name of Peter Livingstone in the Corporate Books;
and the delivery of the certificate of said transfer of
shares of stock,
2. That Unit 1, Lipat Bahay Condominium (amounting to
P2,000,000.00) be transferred through a notarized Deed
of Conveyance in favor of Livingstone for purposes of
registration in the Register of Deeds,
3. That Unit 2, Lipat Bahay Condominium(amounting to
P3,000,000.00) be transferred through a valid Deed of
Conveyance in favor of Livingstone for purposes of
registration in the Register of Deeds,
4. That he be paid the value of Unit 3, Lipat Bahay
Condominium(amounting to P1,000,000.00) in cash, or
be given a similar property with the same value, since the
same is not the property of PRI, as evidenced by Title
registered in the name of a certain Ga Tang,
5. That Unit 4, Lipat Bahay Condominium(amounting to
P2,000,000.00)be transferred through a valid Deed of
Conveyance in favor of Livingstone for purposes of
registration in the Register of Deeds, and that you are
demanded to remit the rents earned from the occupant
since December 31, 2008 amounting to P50,000.00 per
month or a total of P5,500,000.00,
6. That a notarized Deed of Conveyance for the agricultural
land covered by OCT No. 23 be issued in favor of Peter
Livingstone in order to register the same in the Register
of Deeds.

Thus our law firm, in compliance with the interest of our


client, Peter Livingstone, hereby demand your corporation to
fully comply with these final demands in fulfilment of your
obligations, within THIRTY (30) days from receipt of this
letter. Failure to do so, then we are constrained to file the
necessary legal actions in the courts in order to protect the
interest of our client.

We trust that you will give these demands your utmost


priority and attention that we may settle this matter without
need of court intervention.

Sincerely,

Atty. Louella C. Ariola


Roll No. 00011
IBP Lifetime Member No. 00012
PTR No. 1234567, 01-02-18, Baguio City
MCLE Compliance No. III-0000123
_________________________________