WITHOUT PREJUDICE

17 July 2020

_____ Homeowners Association

___

Dear Sir or Madam:

Greetings!

We are writing on behalf of our client Dr. Joel Pantig, for the purpose of demanding access
to his property by allowing him and his contractor to complete the construction of his
reidential property located at ____. In connection herewith, our client is giving the ____
Homeowners Association (HOA) three (3) days from receipt of this letter within which to
comply with his demands.

It must be recalled that in ___ 2020, our client began the construction of his residential
house in your subdivision. As required by your HOA, our client submitted the required pre-
construction documents which include among others, the blue print, perspective, floor plan,
etc. Further, our client deposited the construction bond amounting to P50,)))____. From
then on, our client, with the permission and without any objection or protestations from the
HOA, proceeded in the construction of his residential house.

In ___ 2020, the construction has reached its finishing stage. However, just as when the
structure of his house has neared completion, our client was shocked when he was notified
of a violation of the restrictions imposed by the HOA. For the first time, the HOA raised this
issue of setback or easement requirements. At this point of the construction stage,
rectifying the construction to comply the easement and setback requirements will be costly
and highly prejudicial to our client.

It is the position of our client that the notice was belatedly issued. It was not given a timely
manner that would have cause less inconvenience to our client, or to any homeowners for
that matter. The HOA’s inaction is the proximate cause of this hullabaloo.

On ____ July 2020, our client learned that his contractor was not allowed access into the
subdivision to complete the construction of his house. As a result, our client is severely
burdened of the HOA’s actions. Worse, his concerns were passed from one officer to
another, thus adding salt to injury. While, our client is amenable that his construction bond
may be forfeited, he is willing to compromise. However, to force him to deconstruct what
has been already constructed (at this stage), will be unreasonable given the circumstances
above.

Hence, our client’s demand to allow him to finish the construction of his property without
further delay, by giving him and his contractor’s workers access thereto, is respectfully
reiterated.
Kindly consider this as our client’s final and formal demand. A negative response shall
constrain us to advise our client to elevate the matter to a full blown lawsuit for damages,
injunction, and other available remedies to protect his interests. To avoid a protracted and
stressful litigation, please give this matter your utmost attention.

In the meantime, all our client’s rights are expressly reserved and waives none.