August 31, 2020

Abcd edfg
18TH Avenue
Makati City

We write for and in behalf of our client, Abcd edfg .

This refers to the request for PAYMENT by our client as regards your
Mortgage Loan in the amount of One Hundred Fifty Thousand Pesos (PHP
150,000) plus interests, as stated in your Mortgage Agreement. (Copy of the
said agreement is attached as Annex “A” for your reference).

As a brief background, you and our client entered into a “Mortgage

Agreement on December 04, 2019 of parcel of land, which is more
particularly described as: 15,000 Sq. Meter Land situated at San Juan,
Quezon, Isabela. (A copy of the TCT No. 124538763584, title of the subject
property is hereto attached as Annex “B” for your reference.)

According to the agreement, you have to pay the fifteen thousand pesos
(PHP 15,000) or the equivalent of 10% of the total amount of the mortgage
and/or loan every 4th of the month starting December 2019 until March 04,
2020.

To reiterate, you have paid only a total of three months from the execution of
your contract, and thereafter, you continuously failed to pay the interests of
your mortgage loan in the amount ONE HUNDRED FIFTY THOUSAND
PESOS (PHP 150,000.00) plus the interest already incurred due to your
delayed payment or interest for the months of April, May and August 2020.

Moreover, to our client’s dismay, you issued a post-dated check which was
dishonored by the drawee bank due to insufficiency of funds, hence the
account was declared “closed account”. Details of the check are stated
hereunder:

Account No. Check No. Date Amount

264981208 518520218 January 02, 15,000.00

2020

Our client has also made earnest efforts to follow-up on your payments by
sending you several messages thru your messenger account.

It is for this reason that our client relied in good faith to your express
representations that our client will be paid the fair and equitable amount
due her amounting to ONE HUNDRED FIFTY THOUSAND PESOS (PHP

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150,000.00) plus interests. However, not only that you failed to make good
on its undertaking but much worse is that you could no longer be contacted.

Under Batas Pambansa Blg. No. 22 or the Bouncing Checks Law, a person
who issued a worthless check, that is, when the check, at the time it is
encashed for payment, which must be within ninety days from issuance, is
dishonored by the issuing bank because of insufficient funds, or even when
the account against which the check was drawn was already closed. To wit:

Section 1. Checks without sufficient funds. - Any person who

makes or draws and issues any check to apply on account or
for value, knowing at the time of issue that he does not have
sufficient funds in or credit with the drawee bank for the
payment of such check in full upon its presentment, which
check is subsequently dishonored by the drawee bank for
insufficiency of funds or credit or would have been dishonored
for the same reason had not the drawer, without any valid
reason, ordered the bank to stop payment, shall be punished
by imprisonment of not less than thirty days but not more than
one (1) year or by a fine of not less than but not more than
double the amount of the check which fine shall in no case
exceed Two Hundred Thousand Pesos, or both such fine and
imprisonment at the discretion of the court.

The same penalty shall be imposed upon any person who,

having sufficient funds in or credit with the drawee bank when
he makes or draws and issues a check, shall fail to keep
sufficient funds or to maintain a credit to cover the full amount
of the check if presented within a period of ninety (90) days
from the date appearing thereon, for which reason it is
dishonored by the drawee bank.

Where the check is drawn by a corporation, company or entity,

the person or persons who actually signed the check in behalf
of such drawer shall be liable under this Act.

In view thereof, we heretofore respectfully demand, on behalf of our client,

that you pay the amount of ONE HUNDRED FIFTY THOUSAND PESOS
(PHP 150,000.00) representing your mortgage loan plus interests
amounting to FORTY FIVE THOUSAND PESOS (PHP 45,000.00) accruing
from the time you failed to pay your monthly due.

Note that in case our client will have to commence legal proceedings in order
to secure payment of the debt owing to our client, this letter of demand will
be tendered in court as evidence of your failure to attempt to resolve this
matter. Further, you will be liable for any court costs, attorney’s fees and
damage, including punitive damages.

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This is a FINAL DEMAND. We hope this matter merits your preferential
attention and an action or response to this letter be made not later than
FIFTEEN (15) days from receipt hereof.

Thank you.

Respectfully yours,

Atty. CVBG

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