4 October 2022

JM
Municipality of Danao,

RE: Demand Letter for Sum of Money

Dear Mr.JM:

My client, ____________complained that you failed to settle your

obligation to her and to her Association Sinking Funds. Based on the
surrounding antecedent facts narrated by my client, are as follows, to wit:

On 28 May 2021, you secured loan from my client and from her
Association Sinking Funds the amount of ONE HUNDRED THOUSAND
(Php100,000.00) PESOS with an agreed interest of 5% upon its return on the third
week of June 2021. In order to gain the trust and consent of my client and her
association, you posted and sent to my client your alleged business DTI
Registration and that you needed the money for your grand opening of your
business, that you have 50 swertres lotto outlets in Cebu City, that you have Php
2.5 million being on-hold by the bank by sending to her a captured picture
showing the said amount and that it will be released on the third week of June
2021. Not only that, you showed to my client an alleged rolex submariner worth
Php560,000.00.

Consequently, my client and her association already reposed their trust

and confidence to you that the transaction that she entered into between you was
not dubious, as such, she agreed and convinced her association when you
requested the said loan amount.

On June 19, 2000, when my client made a follow-up on your payment as

you promised, you simply replied to her through text by saying:

“Hello tita. Sorry super busy lately. Money is okay na. Need
lang nku siya e OTC kay e butang nkus lain bank.
Deactivated man gihapon akong online banking”

Unfortunately, many follow-ups were made by my client in order for you

to comply your promised and pay your obligation but to no avail. My client even
personally went to your family in Tuburan hoping to meet you there or at least
to know your whereabout but you remain elusive.

In my presumption, the surrounding facts narrated and based on the

pieces of evidence that my client produced, this is a palpable act of “Estafa”
under Article 315of the Revised Penal Code (Swindling and Other Deceits).

To give you a better view:

“Estafa - is a criminal offense wherein a person defrauds

another by any of the following means: (1) by
 unfaithfulness or abuse of confidence; (2) by deceit;
or (3) fraudulent means. x x x

The two basic elements common to all forms of Estafa are:

(1) Fraud; and (2) Resulting damage or intent to cause
damage capable of pecuniary estimation.”

- x x x-

It was true that it is the constitutional proscription that no person shall be

imprisoned for non-payment of debt but the law punishes the criminal actuation
and the legal consequences is involving JAIL TERMS OR IMPRISONMENT for
violation of Article 315 (Estafa), and I cannot prevent my client to institute such
action since she had already cause of action to file criminal charges against you.
Also, my client has other remedy in order to secure satisfaction of her remedy
under Rule 57 of the Rules of Court through WRIT OF ATTACHMENT, wherein
immediate attachment of properties, monies or pension held by FRIENDS,
PARENTS AND/OR RELATIVES of delinquent debtors or under said debtor’s
name to satisfy.

If I were you Mr JM, to avoid the burden of the legal consequence you are
going to deal with, I suggest you to settle your account with my client and to pay
all the accrued interest thereof. You may contact me thru my mobile numbers
099999999 or 091111111 or directly contact my client for further amicable
settlement.

I am giving you ten (10) calendar days upon receipt of this letter, to
comply with your obligation to my client, otherwise, as much to my regret, my
client will pursue her criminal and civil complaint against you to recover any
damages that she incurred.

Please give this demand your preferential attention to avoid

inconvenience on your part.

Cebu City, Cebu, Philippines, October 5, 2022.

ATTY.
Counsel for Client
At my instance:

client