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June 08, 2021

Arturo N. Interior
Isometric Builder and Land Development
#29 Alchan St., Barangka Itaas,
Mandaluyong City

Subject: Demand to Construct Townhome

Dear Mr. Interior,

Greetings! The undersigned counsel writes on behalf of my client, Mr.


Gregonito Gawaran (“Gawaran”), who referred to me the matter of your
agreement.

It has come to our attention that on 17 November 2011, you and Mr.
Gawaran entered into an agreement. Correspondingly, the agreement states that in
addition to the lots you have given, you will also construct a house on the given
lots provided that you will be given enough time considering the circumstances
your company had undergone.

“Na sumasang-ayon din ako na magkaroon din ng sapat na panahon si


GINOONG INTERIOR upang maitayo rin niya ang nasabing TOWNHOME at
aking nababatid ang kanyang kagipitan sa nasabing proyektong aming
napagkasunduan.”

For easy reference, the agreement dated 17 November 2011 is hereto


attached as Annex “A”.

It has been years since you have entered into the aforementioned agreement.
However, to date, you have not even started with the construction of the
Townhome/s you have committed or promised to perform.

Our client has been patient and been demanding from you to perform your
obligation to him. Yet, despite repeated demands you have failed, if not, refused to
comply with your obligation to construct the house on the lot that you have
provided.

Unfortunately, as the records reveal, as of current date, you have failed to


comply with your commitments under the said agreement. Despite our clients’
exhaustive attempts to reach you and communicate with you, they have not
received any update nor any response from you regarding such matter

Hence, FORMAL and FINAL DEMAND to fulfill the obligation to


construct the house within Fifteen (15) days from receipt of this letter.
Should you fail to heed the foregoing demand, our client shall not hesitate to
pursue all the necessary legal actions against you to protect our client’s rights and
interests and further hold you liable for damages and attorney’s fees.

We trust that this matter shall merit your utmost and immediate attention to
spare the parties the rigors of court litigation.

Thank you very much.

Yours truly,

ATTY. PAOLO MIGUEL G. RIGUERRA

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