BORJA ₰

VILLONES
Kertz Apartment
Brgy. 77 Fatima Village,
Marasbaras, Tacloban City 6500
Office Mobile No. 09338621473
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May 3, 2018

MR. & MRS. JOEY and JENNY REGELISA

Zone 3, Sta. Fe, Leyte

MR. & MRS. REGELISA:

GREETINGS!

The undersigned’s client, LEONIL M. EPIL through its authorized

representative BERNARDO EPIL referred for legal action the matter of your
continued refusal to execute an appropriate instrument that would cover the
transactions that took place between you and my client involving a property
located at Brgy. San Isidro, Sta. Fe, Leyte, Leyte designated as Lot No. 346
covered by Katibayan Ng Orihinal na Titulo Blg. P-62174 registered under the
name of JOEY REGELISA married to JENNY REGELISA.

Records would show that the above-described property had long been
purchased by my client in installment basis with a total amount of Two
Hundred Forty Thousand (P240,000) which amount was duly received and
acknowledged by you. The said sale transaction was not covered by a
document evidencing the same because my client had trusted you, as his
relative, that you will honor the said sale transactions. Unfortunately, you are
now denying the said sale transaction BUT you admitted/acknowledged that
you have taken such amount from my client and used the said property as
security thereby making the said transaction one of mortgage.

Be that it may be, it is now the intention of my herein client to have a

Deed of Real Estate Mortgage executed to protect their rights over the subject
property. It can be recalled that you have admitted that you have mortgaged
the subject lot in favor of herein client before the Barangay Chairman HON.
ALLAN SEVILLA of Brgy. San Isidro, Sta. Fe, Leyte in a conciliation/mediation
conducted on_______________. Thus, the execution of an appropriate
instrument i.e Deed of Real Estate Mortgage to protect the rights of herein
client is just and proper under the circumstances. Refusal to execute the same
would be unjust and prejudicial to the rights of my client.

In view of the foregoing, it is respectfully sought after you to execute a

Deed of Real Estate Mortgage in favor of my client within the period of five (5)
days from the receipt of this letter or you may contact the undersigned through
her mobile number 09157519220 for the execution of the same, otherwise we
will be constrained to file the appropriate civil/criminal actions against you
and let the Court order you to execute the same and further order you to pay
the necessary penalties.

Appreciating your giving attention to this matter with utmost preference.

Truly Yours,
ATTY. SHARON R. VILONES
Counsel for Mr. Epil

With our conformity:

LEONIL M. EPIL
Client
August 26, 201

MR. & MRS. JOEY and JENNY REGELISA

Zone 3, Sta. Fe, Leyte

MR. & MRS. REGELISA:

GREETINGS!

The undersigned’s client, LEONIL M. EPIL referred for legal action the
matter of your continued refusal to execute a Deed of Sale of a property located
at Brgy. San Isidro, Sta. Fe, Leyte, Leyte designated as Lot No. 346 covered by
Katibayan Ng Orihinal na Titulo Blg. P-62174 registered under the name of
JOEY REGELISA married to JENNY REGELISA.

Records would show that the above-described property had long been
purchased by my client in installment basis with a total amount of Two
Hundred Forty Thousand (P240,000) which amount was duly received by you.
The said sale transaction was not covered by a document evidencing the same
because my client had trusted you, as his relative, that you will honor the said
sale transactions.

However, it is now the wish of my herein client to have a Deed of Sale

executed to protect their rights over the subject property. Unfortunately, it
came to my client’s knowledge that you are now denying the said sale
transaction and instead claiming that the property was just mortgaged.
However, it was clear as the blue sky that the transaction you have entered
with my client is one of sale and not mortgage.

Considering the ownership by Leonil of the property, it is respectfully

sought after you to execute a Deed of Sale in favor of my client within the
period of five (5) days from the receipt of this letter Or you may contact the
undersigned through her mobile number 09157519220 for possible
arrangement/settlement on this matter. Otherwise we will be constrained to
file the appropriate civil/criminal actions against you.

Appreciating your giving attention to this matter with utmost preference.

Truly Yours,

ATTY. SHARON R. VILONES

Counsel for Mr. Epil

With our conformity:

LEONIL M. EPIL
Client