Republika ng Pilipinas

LALAWIGAN NG NUEVA ECIJA

Lungsod ng Palayan
- o oOo o -

TANGGAPAN NG PANLALAWIGANG PAMBATAS

(Provincial Legal Office)

December 20, 2022.

RE: DEMAND LETTER

JOEY SANTIAGO
RODERICK M. BOŇON
RJBS Enterprises
Brgy. Tibagan, Bustos, Bulacan

We write this letter in connection with the incident that transpired last 2 November
2022.

Our clients, Richelle Joy Clamonte Javier and her driver Sherwin Capulong Allarde, in-
formed this office that due to the negligence of your driver, Roderick Boñon, they sus-
tained damages amounting to P 1,117,260.00.

Your driver admitted in the police blotter dated 3 November 2022 that the proximate
cause of the accident was his uncalculated act of stepping on the break of the vehicle
he was driving which resulted to the swaying of his trailer, and hitting the cab owned
by our client.

We understand that the criminal aspect of this case, Physical Injury, is already filed in
court, but our client reserves her right to prosecute the civil action independently of the
criminal action.

You are vicariously liable for the negligent act of your employee, Roderick Boñon,
since the accident transpired while he was in the performance of his function as your
truck driver.

Our clients demand that you shoulder the cost of the repair of their cab, and that it
be repaired in a reputable machine shop of their choice, or you replace their to-
tally damaged cab with a new one if repair cost will be more than the cost of brand
new cab.

In view thereof, on behalf of our clients, we most respectfully request that you comply
with their demand within 10 days from receipt of this letter, otherwise we will be com-
pelled to file this case in court.

Please give this matter your immediate and preferential attention. We trust you will see
your way clear towards the prompt and amicable settlement of our clients’ plainly valid
demand in order for you to avoid the inconvenience, expenses and embarrassment of
litigation.

Sincerely,

ATTY. ELIJAH B. BACTOL

Legal Officer II