December 21, 2020

RD CAYAMOMBAO D. DIA
Regional Director, Region IX (Zamboanga Peninsula)
Department of Public Works and Highways
Tetuan, Zamboanga City

Thru: DE VERONICO O. MICARANDAYAO

Officer-in-charge, DPWH Zamboanga del Norte
3rd District Engineering Office
Segabe, Piñan, Zamboanga del Norte

Sir/Madam:

Gloria en excelcis Deo!

The undersigned attorneys-in fact for and in behalf of the Heirs of Victor Recamara, absolute
owner and lawful possessor of a parcel of land known as Lot No. 5635-C of the subdivision plan
Psd-48303, being a portion of Lot 5635 of the cadastral survey of Dipolog, L.R.C. situated in
Barrio Dansullan, (now New Sicayab), Polanco, Zamboanga del Norte containing a total area of
THIRTY THOUSAND THIRTY-THREE SQUARE METERS (30, 033 sq. m.) covered under
TCT no. T-7168, hereby demand your good office for JUST COMPENSATION with legal
damages of portions of the said land being used by the REPUBLIC-DPWH REGION IX for
public purpose in the following road projects:

1. Road Widening – Primary Roads, Dipolog-Punta-Dansullan-Sergio

Osmeña, Zamboanga del Norte including ROW, K1855+877.00-
K1862+900.00, net length: 13.84 Lane Km. 6, 920.95 Ln.m./6.921 Km,
Zamboanga del Norte (taken by the government on year 2020); and
2. Inner lanes of the above mentioned (taken by the government on
_____________________).

Further, the following are hereby demanded and prayed:

1. Just compensation of the 2 projects mentioned above;

2. Interest as mandated in Republic v. Court of Appeals, 433 Phil. 106 (2002);
3. Legal Interest capped at 12% per annum as mandated in Republic v
Evergreen Manufacturing Corporation, GR Nos. 218631, 218628, reckoned
from the date of taking to the final payment thereof;
4. Damages to improvements;
5. That the said roads be parcellary surveyed; and
6.. Segregate the affected lots for the purpose of registering them in favor of
the Government- Republic, DPWH-IX.
Under Article III, Section 9 of the 1987 Constitution, private property shall not be taken for
public use without just compensation. The identified roads are already taken by the government
but no just compensation has been received by the owners thereof. Hence, through this letter the
undersigned hereby demands immediate payment of the above mentioned.

Attached herewith are the Special Power of Attorney executed in favor of the undersigned and a
certified true copy of the owner’s duplicate title.

More power and God bless!

Feliz Navida et Prospero Año y Felicidad!

Yours sincerely;

JAY CALALANG MANATAD

HELEN RECAMARA CHIPOCO