Вы находитесь на странице: 1из 6

05 October 2015

Dear:

Our Client Angel Umali, has referred to this office, for immediate legal
action, relative to your agreed sale, prestation and execution of corresponding
deed of conveyance over your real property, which is subject for sale (House
and Lot, located at 23 Emilio Jacinto St. Sta. Cruz Lubao, Pampanga).

Evidence at hand disclosed that the amount of Php 2,020,000.00 were


paid by our client leaving the balance price of Php 2,430,000.00. The agreed
purchase price is pegged at Php 4,500,000.00. Our client dutifully paying the
balance price of Php 2,430,000.00, in your favor, however, you intently ignored
and refused to accept the payment of the balance price, for reasons known only
to you. Further, you failed to execute the required deed of sale, which to all
indication you are violating your prestation and agreement with our client.

Our client had made several oral and written demand upon you to make
the necessary deed of conveyance, unfortunately, you ignored it. Thus, this
letter serves as a FORMAL AND FINAL DEMAND upon you, within FIVE (5)
DAYS from receipt hereof, to execute the deed of conveyance and accept the
payment of balance price. Otherwise, and much to our regret, we have no
alternative save to file the corresponding legal action against you before the
court, in order to protect the rights and interest of our client.

Kindly give this letter/demand preferential attention to avoid


inconvenience, court litigation, payment of damages, attorneys fees and the
like.

Truly yours,

Counsel for Angel Umali

At my instance:

ANGEL UMALI
Buyer

October 5, 2015
Dear Mr. :

I write on behalf of my Client Alex Patrol, of Brgy. Sto. Tomas Lubao,


Pampanga, anent the dishonored BDO Checks you made, signed and issued in
favor of Ms. Manalang, as payment of the liabilities/obligation of Mr. Gerardo
Mostiero.

Per evidence at hand disclosed, you and Mr. Mostiero went to the
residence of our client at Sto. Tomas Lubao, Pampanga, and offer to Ms.
Manalang that you will assumed and pay the obligation of Mr. Mostiero in the
total amount of Php 1,580,000.00. You make representation that you will issue
the corresponding checks (from March 10, 2015 up to October 10, 2015) in
favor of Ms. Manalang. You assure and undertake that the BDO Checks you
issued were properly funded. However, when the first BDO Checks, dated
March 10, 2015, in the amount of Php 240,000.00 was presented before the
drawee bank for payment, the said check was dishonored for reason of Account
Closed.

Our client had made several oral and written demand upon you to make
the necessary payment unfortunately, you ignored it. Thus, this letter serves as
a FORMAL AND FINAL DEMAND upon you, within FIVE (5) DAYS from receipt
hereof, to pay and/or redeem the value of subject check. Otherwise, and much
to our regret, we have no alternative save to file the corresponding legal action
against you before the court, in order to protect the rights and interest of our
client.

Kindly give this letter/demand preferential attention to avoid


inconvenience, court litigation, payment of damages, attorneys fees and the
like.

Truly yours,
Counsel for Alex Patrol

At my instance:

MR. ALEX PATROL


Client

October 5, 2015

Dear Mr.:
I write on behalf of my Client Arnold Matula, of Brgy. Remedios Lubao,
Pampanga, relative to your act of entering/occupying their property, by means
of force, stealth, strategy and the like, to the damage and prejudice of our
client, the lawful and registered owner of subject property.

Per evidence at hand disclosed that sometime in November 2014, Mr.


Jesus T. Cabrera, together with his relative, visited their property. Said
property was unattended and unoccupied by Mr. Kenshin and family. However,
our client was surprised to learn that their property was unlawfully occupied
by you. When confronted anent your unlawful act, you told them that you will
not leave and told them to go to court. Per investigation and inquiry, conducted
by our client, from the people residing near subject property, it was uncovered
that while their property was unattended, thru stealth, misrepresentation,
deceit and pretending to be the owner, you forcibly entered the subject
property.

In this light, I am notifying you to vacate at once the subject premises,


and surrender its possession in favor of our client. Failure on your part to heed
our plainly, just and valid demand, I have no recourse save to file the
necessary action before the court to protect the rights and interest of our
client.

Respectfully yours,

THIRDEE L. MEDRANO
Counsel for Arnold Matula

At my instance:

MR. ARNOLD MATULA


Client
05 October 2015

Dear Mr. Medrano:

Our Client Ramanses Sprikitik, has referred to this office, for immediate
legal action, relative to your agreed sale, prestation and execution of
corresponding deed of conveyance over your real property, which is subject for
sale (House and Lot, located at 44 Teresa Village, Angeles City).

Evidence at hand disclosed that the amount of Php 2,020,000.00 were


paid by our client leaving the balance price of Php 2,430,000.00. The agreed
purchase price is pegged at Php 4,500,000.00. Our client dutifully paying the
balance price of Php 2,430,000.00, in your favor, however, you intently ignored
and refused to accept the payment of the balance price, for reasons known only
to you. Further, you failed to execute the required deed of sale, which to all
indication you are violating your prestation and agreement with our client.

Our client had made several oral and written demand upon you to make
the necessary deed of conveyance, unfortunately, you ignored it. Thus, this
letter serves as a FORMAL AND FINAL DEMAND upon you, within FIVE (5)
DAYS from receipt hereof, to execute the deed of conveyance and accept the
payment of balance price. Otherwise, and much to our regret, we have no
alternative save to file the corresponding legal action against you before the
court, in order to protect the rights and interest of our client.

Kindly give this letter/demand preferential attention to avoid


inconvenience, court litigation, payment of damages, attorneys fees and the
like.

Truly yours,

Counsel for Ramanses Sprikitik

At my instance:

RAMANSES SPRIKITIK
Buyer

October 5, 2015
Dear :

I write on behalf of my Client Alex Santos, of Brgy. Baruya Lubao,


Pampanga, anent the dishonored BDO Checks you made, signed and issued in
favor of Ms. Manalang, as payment of the liabilities/obligation of Mr. Gerardo
Mostiero.

Per evidence at hand disclosed, you and Mr. Mostiero went to the
residence of our client at Baruya, Lubao, Pampanga, and offer to Ms. Manalang
that you will assumed and pay the obligation of Mr. Mostiero in the total
amount of Php 1,580,000.00. You make representation that you will issue the
corresponding checks (from March 10, 2015 up to October 10, 2015) in favor of
Ms. Manalang. You assure and undertake that the BDO Checks you issued
were properly funded. However, when the first BDO Checks, dated March 10,
2015, in the amount of Php 240,000.00 was presented before the drawee bank
for payment, the said check was dishonored for reason of Account Closed.

Our client had made several oral and written demand upon you to make
the necessary payment unfortunately, you ignored it. Thus, this letter serves as
a FORMAL AND FINAL DEMAND upon you, within FIVE (5) DAYS from receipt
hereof, to pay and/or redeem the value of subject check. Otherwise, and much
to our regret, we have no alternative save to file the corresponding legal action
against you before the court, in order to protect the rights and interest of our
client.

Kindly give this letter/demand preferential attention to avoid


inconvenience, court litigation, payment of damages, attorneys fees and the
like.

Truly yours,

Counsel for Ramanses Sprikitik

At my instance:

MR. ALEX SANTOS


Client

October 5, 2015
Dear :

I write on behalf of my Client Arnold Kenshin, of Brgy. Sta. Cruz Lubao,


Pampanga, relative to your act of entering/occupying their property, by means
of force, stealth, strategy and the like, to the damage and prejudice of our
client, the lawful and registered owner of subject property.

Per evidence at hand disclosed that sometime in November 2014, Mr.


Jesus T. Cabrera, together with his relative, visited their property. Said
property was unattended and unoccupied by Mr. Kenshin and family. However,
our client was surprised to learn that their property was unlawfully occupied
by you. When confronted anent your unlawful act, you told them that you will
not leave and told them to go to court. Per investigation and inquiry, conducted
by our client, from the people residing near subject property, it was uncovered
that while their property was unattended, thru stealth, misrepresentation,
deceit and pretending to be the owner, you forcibly entered the subject
property.

In this light, I am notifying you to vacate at once the subject premises,


and surrender its possession in favor of our client. Failure on your part to heed
our plainly, just and valid demand, I have no recourse save to file the
necessary action before the court to protect the rights and interest of our
client.

Respectfully yours,

Counsel for Arnold Kenshin

At my instance:

MR. ARNOLD KENSHIN


Client

Вам также может понравиться