Alano law office

Atty. Joseph rod allan c. alano

138 san Antonio ave. san Antonio valley 1
Paranaque city, Philippines
(02) 6595005

6 October 2019

KFC Philippines
G/F Ramcar Center Building
80-82 Roces Avenue
Diliman, Quezon City

Attention: The Management

Re: Demand for Compensation for Injuries suffered on May 12,

2019 at your San Antonio Valley 1 Branch

Gentlemen/Mesdames:

I write on behalf of my client, Mr. Richard Celecio, Jr. regarding the injuries which he
suffered from as a result of his sitting on a defective chair located within your outlet located at San
Antonio Valley I, Paranaque City on May 12, 2019.

In sum, on May 12, 2019 and while my client was sitting on a chair at the aforementioned
outlet, the same suddenly collapsed causing him to use my right forearm to support my fall. As a
result thereof, I suffered injuries to both my right forearm and my back causing me severe pain
and difficulty in movements which persist to the current day. I’ve had to go through medical
examinations, undergo x-rays, take medications and undergo chiropractic therapy just to alleviate
the pain and rehabilitate my injuries. Further, I had to miss work from May 12-20, 2019 and from
May 31-June 1, 2019 just to heal from my injuries and incurred further expenses/travel costs just
to substantiate the expenses that I had to incur as a result of your negligence. Finally, the trauma
of the accident has rendered me anxious and apprehensive when sitting on chairs of other
establishments in the fear that they may also be defective and cause further injury to me.

All told, I’ve incurred the following expenses / suffered the following damages in relation
to your negligence:

1. Medical Expenses (Total: PHP 181,300.00)

a. Initial therapy session (May 30, 2019) – PHP 4,900/ session
b. Future treatment sessions – 36 sessions / PHP 4,900 session

2. Lost Wages (Total: PHP 13,000.00)

a. Sick Leaves dated: May 12-20, 2019 and May 31-June 1, 2019

3. Transportation Costs (Total: PHP 47,000.00)

a. Hospital (for medical treatment)
b. Barangay (for blotter)
c. Customer Welfare Office (for settlement meetings)
d. Medical City (for medical certificates)
e. KFC Outlet (for settlement letters)
 Alano law office
Atty. Joseph rod allan c. alano
138 san Antonio ave. san Antonio valley 1
Paranaque city, Philippines
(02) 6595005

f. Chiropractic Doctor (for treatments)

g. Therapy – 36 treatments/sessions

4. Moral Damages as a result of physical suffering, mental anguish, fright and serious anxiety
(PHP 500,000.00)

All told, my client has suffered damages in the amount of Seven Hundred Forty One
Thousand Three Hundred Pesos (PHP 741,300.00) as a result of your negligence. To add insult
to injury, and despite my client’s tendering of two (2) demand letters on May 22, 2019 and June
4, 2019, respectively, your personnel have utterly and completely failed to act thereon despite my
client properly furnishing the necessary documents to substantiate his claim. My client has
advised me that he intends to expose this incident on social media to warn the public of the
dangers in KFC outlets in the Philippines but I advised him to desist in the meantime as we trust
that you will duly and promptly act on his claim.

Therefore, premises duly considered, demand is hereby made upon you to pay the
amount of Seven Hundred Forty One Thousand Three Hundred Pesos (PHP 741,300.00), within
ten (10) calendar days from receipt of this letter, to duly compensate my client for the injuries he
suffered from your negligence. Failure on your part to heed this demand shall constrain my client
to avail of the necessary legal and judicial remedies available to him.

We trust that you shall give this matter your preferential attention. Should you have any
questions, please do not hesitate to contact the undersigned at rjalano.law@gmail.com or at
telephone number (02) 6595005.

Very truly yours,

Atty. Joseph Rod Allan C. Alano

Alano Law Office
138 San Antonio Avenue, San Antonio, Paranaque City