ANNNEX E

LABIS LAW OFFICE

4A MACROHON BUILDING, CAMPANER STREET, ANTIPOLO CITY, RIZAL
(062) 955-0683/09177091484 labis.swap87@gmail.com

January 20, 2020

BCD PARTNERSHIP
Mayamot, Antipolo City

GREETINGS OF PEACE!

Dear Madam:

Our client, ABC Trading, Inc. represented by Mr. Noel S. Cruz-Herrera as President and CEO with
address at 437 Luntian St., Brgy Dalig, Antipolo City, has referred to us for appropriate legal action
regarding your PRINCIPAL OBLIGATION in the amount of ONE MILLION FIVE HUNDRED SIXTY
THREE THOUSAND ONE HUNDRED FOUR AND 22/100 (PHP 1,563,104.22) in Philippine Currency
representing your arrears on purchases of various handicraft materials from January to
December 2019 which is past due and demandable.

Notably, several BDO postdated checks were issued in favor of our client. Such checks were
dishonored by the bank for being “Drawn against Insufficient Funds”. Still, after repeated
demands, the settlement was never satisfied. Adding insult to injury, issuance of the Union Bank
postdated check in lieu of the bounced BDO postdated checks was rejected for being an
“Account Closed”.

We are promptly serving you this FINAL NOTICE OF DEMAND in order to settle or pay your
outstanding obligation or the equivalent total amount of ONE MILLION FIVE HUNDRED SIXTY
THREE THOUSAND ONE HUNDRED FOUR AND 22/100 (PHP 1,563,104.22) Philippine Currency
within SEVEN (7) DAYS upon receipt hereof. Should you failed to do so, much to our regret we
will be constrained to take the necessary legal action to protect the interest of our client.

We are optimistic that within the period SEVEN (7) DAYS you will have enough time to reflect on
the consequences of having a protracted litigation . It is our best interest that our client and its
debtor be saved from unnecessary costs, time and effort in a lengthy court proceeding by
resorting into an amicable settlement.
Needless to state, in the event of suit, we shall equally hold you liable for further interests, cost
of suit, 25% attorney’s fee and other expenses a court litigation would necessarily entail.

In the event a civil action will pursue, a complaint of SUM OF MONEY WITH DAMAGES will be
filed in the regular courts of Antipolo City and at the same time an application for the
PROVISIONAL REMEDY OF WRIT OF PRELIMINARY ATTACHMENT, will be served to you together
with the complaint by the court to LEVY, ATTACH, or Seize your personal properties including
your bank accounts and salaries, if any, pending trial of the case. The aforementioned properties
shall answer proportionately for your outstanding obligation aforecited-above plus interest,
penalty and the twenty-five percent (25%) attorney’s fees.

We therefore urge you to give this matter your serious and preferential attention in order to
prevent this matter from getting out of control and avert the inconvenience and embarrassment
that may arise from our contemplated legal actions.

While we recommend that you resort to a more sensible means of settling your account, should
you fail again to heed our advice, we will pursue our client’s cause with outmost fervor. In any
case that you will have decided to settle your obligation, please feel free to call our client.

Anticipating therefore your favorable response.

Very truly yours,

ATTY. WARLITO LABIS

Legal Counsel
 ABC TRADING, INC
437 Luntian St., Brgy Dalig, Antipolo City

March 18, 2019

BCD PARTNERSHIP
Mayamot, Antipolo City

GREETINGS!

Dear Madam:

Please be informed that BDO postdated check no. 000001 scheduled for encashment on
March 15, 2019, issued by BCD Partnership to ABC Trading, Inc., in the amount of FIVE
HUNDRED THOUSAND PESOS (Php 500,000.00) was dishonored by the bank on
March 16, 2019 upon deposit.

In this regard, cognizance of the good will and camaraderie practiced in the trading
industry and in accord with our agreement, kindly settle the above amount immediately
relative to the purchase of various handicraft made last January 15, 2019.

Thank you.

Very truly yours,

Noel S, Cruz-Herrera
President and CEO
ABC Trading, Inc.
 ABC TRADING, INC
437 Luntian St., Brgy Dalig, Antipolo City

June 18, 2019

BCD PARTNERSHIP
Mayamot, Antipolo City

GREETINGS!S

Dear Madam:

This is to inform you that BDO postdated check no. 000002 scheduled for encashment
on June 15, 2019, issued by BCD Partnership to ABC Trading, Inc., in the amount of EIGHT
HUNDRED THOUSAND PESOS (Php 800,000.00) was dishonored by the same bank on June
17, 2019 upon deposit.

In relation therewith, payment for the transaction made on January 15, 2019 as
reflected in BDO postdated check no. 000001 in the amount of FIVE HUNDRED THOUSAND
PESOS (Php 500,000.00) and purchases made on March 15, 2019 in the amount of THREE
HUNDRED THOUSAND PESOS (Php 300,000.00) remains unsettled.

Hoping for utmost cooperation on the matter.

Thank you.

Very truly yours,

Noel S, Cruz-Herrera
President and CEO
ABC Trading, Inc.
 ABC TRADING, INC
437 Luntian St., Brgy Dalig, Antipolo City

September 6, 2019

BCD PARTNERSHIP
Mayamot, Antipolo City

GREETINGS!

Dear Madam:

Be informed that BDO postdated check no. 000003 scheduled for encashment on
September 1, 2019, issued by BCD Partnership to ABC Trading, Inc., in the amount of ONE
MILLION FIVE HUNDRED SIXTY THREE THOUSAND ONE HUNDRED FOUR AND
22/100 (PHP 1,363,104.22) was dishonored by the same bank on September 5, 2019 upon
deposit.

In connection with the above, payment for the transaction made on January and March
15, 2019 as reflected in BDO postdated check no. 000002 in the amount of EIGHT HUNDRED
THOUSAND PESOS (Php 800,000.00) and purchases made on July 1, 2019 in the amount of
FIVE HUNDRED SIXTY THREE THOUSAND ONE HUNDRED FOUR PESOS and 22/100
CENTAVOS (Php 563,104.22) remains unsettled.

At this juncture, it just and necessary that the long-overdue unsettlement accounts be
paid at once. Thank you.

Very truly yours,

Noel S, Cruz-Herrera
President and CEO
ABC Trading, Inc.
 ABC TRADING, INC
437 Luntian St., Brgy Dalig, Antipolo City

December 23, 2019

BCD PARTNERSHIP
Mayamot, Antipolo City

GREETINGS!

Dear Madam:

Sad to say, BDO postdated check no. 000004 scheduled for encashment on December
20, 2019, issued by BCD Partnership to ABC Trading, Inc., in the amount of ONE MILLION
FIVE HUNDRED SIXTY THREE THOUSAND ONE HUNDRED FOUR AND 22/100 (PHP
1,563,104.22) was dishonored by the same bank on December 20, 2019 upon deposit.

In connection with the above, payment for the transaction made on January 15, March
15 and July 1, 2019 as reflected in BDO postdated check no. 000003 in the amount of ONE
MILLION THREE HUNDRED SIXTY THREE THOUSAND ONE HUNDRED FOUR AND
22/100 (PHP 1,363,104.22) and purchases made on December 2, 2019 in the amount of TWO
HUNDRED THOUSAND PESOS (Php 200,000.00) remains unsettled.

Having exhibited leniency, compassion and humanity in dealing with BCD

Partnership arrears which is overdue for quite a long time, with heavy heart, prior to availment
legal remedies, we are now serving this letter as a final demand for the settlement of your
outstanding balance at once.

Very truly yours,

Noel S, Cruz-Herrera
President and CEO
ABC Trading, Inc.
 ABC TRADING, INC
437 Luntian St., Brgy Dalig, Antipolo City

January 6, 2020

BCD PARTNERSHIP
Mayamot, Antipolo City

GREETINGS!

Dear Madam:

Sad to say, Union Bank postdated check no. 000001 scheduled for encashment on
January 3, 2020, having a total amount of ONE MILLION FIVE HUNDRED SIXTY THREE
THOUSAND ONE HUNDRED FOUR AND 22/100 (PHP 1,563,104.22) which was issued by
BCD Partnership to ABC Trading, Inc., in replacement for the several issued bounced BDO
postdated checks, was dishonored by the Union Bank on the same date for being “Drawn
Against Insufficient Fund” and subsequently for “Account Closed”.

Needless to say, having given BCD Partnership the luxury of time to settle overdue
accounts, we are now obliged to avail of the legal remedies that is appropriate for this matter.

Very truly yours,

Noel S, Cruz-Herrera
President and CEO
ABC Trading, Inc.