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A prospective client, ABCDE CORPORATION, sought your advice on the

demand letter it received, which reads:

February 12, 2023

ABCDE CORPORATION
The Highest Tower, Don F Ortigas Jr. Ave.,
Ortigas Pasig City

Gentlemen:

We write you this letter on a matter which, we believe, deserves your most urgent
attention and concern.

As it happened, your company retained the services of our client 12345 Freight
Forwarding Company to act as your duly accredited broker for several shipments you
imported to the Philippines. Particularly, for your January 2023 shipments, you have
unpaid brokerage fees amounting to Php. 5,000,000.00. A copy of the statement of
account is hereto attached for your reference.

Moreover, as partial payment for the above amount, you issued to our client Bank of the
Philippine Islands Check no. 0000111 dated 01 February 2023 amounting to Php.
2,500,000.00. However, the check was dishonored upon present for payment for having
been drawn against a closed account. Attached hereto is a copy of the check for you
reference.

Thus, FINAL DEMAND is hereby made upon you and/or your Company to: a.) Pay
your outstanding unpaid brokerage fees amounting to Php. 2,500,000.00; b.) make good
the value of the check amounting to Php. Php. 2,500,000.00 within five (5) days from
receipt of this letter. Otherwise, much to our regret, we shall be constrained to file civil
and criminal complaints against you including violation of Batas Pambansa Blg. 22 or
the Bouncing Checks Law.

Very truly yours,

For the Firm,

ATTY. JUAN DELA CRUZ

As the lawyer for the Corporation, prepare the following:

1.) Draft Q and A of the possible questions you might ask your
client;
2.) What are the applicable laws and possible defenses against in a
BP 22 complaint?
3.) Draft the complaint affdaivit and the counter-affidavit/answer
on the BP 22 case plus all other necessary documents to file the
same in court.

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