February 10, 2021

JENNIFER ANNE FAJARDO

7126 General Ricarte Street
South Combo, Makati City

Breach of Contract Demand Letter

I am writing you in behalf of my client, MS. CARMELITA V. MANDARIO,

residing at Collat Riverside, Masinloc Zambales pursuant to the contract titled
“CONDITIONAL SALE” dated 12 June 2017 in Makati City (“Agreement”), you
have conducted yourself in such a way that has breached this Agreement due to
the following actions stipulated therein:

(ii) That the full payment of amount is until 2019.

(iii) That the amount of Two hundred thousand pesos only(P200,000.00)

Philippine currency, will be given within Jun 2017 – May 2018

While we prepare to file a lawsuit against you for the mentioned claims, it is
hopeful that a mutually acceptable resolution outside of a publicly filed litigation
can be achieved.

Unless the aforementioned issues are resolved, this letter formally places you on
notice of the remedies for a breach of contract including but not limited to:

(1)Rescission and reformation: This remedy is used when parties agree to

enter into a contract mistakenly, fraudulently, or due to influence and coercion. If the
court concludes that there has been a material breach of contract or an offense serious
enough to defeat the primary purpose of the Contract, then the court will approve
termination of the Contract.
(2) Compensatory Damages: These are divided into two categories, i.e.,
General and Special damages. General damages are awarded to cover the losses connected
to the breach of contract directly. In contrast, Special damages are awarded to cover any
losses incurred by the non-breaching party.
(3) Restitution: Damages may be available for a breach that is considered
nonmaterial or partial; this means that the Party that has suffered the violation has
experienced some degree of financial damage but not to the extent that the primary
purpose of the contract was destroyed. Restitution is meant to restore the injured Party
to the position occupied before the breach.
 (4) Specific performance: under particular performance, the party in breach of
the contract has to perform its duties as specified in the contract. Specific performance is
customarily used when money damages are not suitable to compensate the plaintiff.
(5) Money damages: refers to the monetary payments paid by the breaching
party for violating the terms of the contract. Subject to the nature of the breach, the court
may rule that the plaintiff be rewarded the full or partial amount that they would have
otherwise have received had the contract gone to completion. There are two types of
money damages i.e.
Compensatory damages: This is the amount of money paid by the breaching
Party to cover the loss incurred by the other party due to the breach of contract.
Punitive Damages: punitive damages, unlike compensatory damages, are
rewarded for punishing the party in breach of the contract to deter them from committing
similar acts.

You have a legal obligation to maintain and preserve any and all documents,
materials, and information, in any form whatsoever, that may be potentially
relevant to the subject matter, or discoverable in any potential action arising
from, this breach.

It is in the best interest of both parties to resolve this matter as soon as possible. If
there is no response by March 10, 2021 then it shall be our right to pursue any
and all available legal and equitable remedies, including, but not limited to,
instituting formal litigation proceedings against you.

Please contact me or my client as soon as you receive this notice, so that we can
arrange to have proper resolution as soon as possible. Failure to which, We shall
pursue legal actions against you.

Very truly yours,

ATTY/ENGR. RICHARD V. GOMEZ