Arlyn Dimal Pangan

May 16, 2023

Ms. VENERISSA CALLOS

Property Administrator
Capri Oasis Pasig Condominium Corporation

Thru : MS. LOUISE ANN R. BARRANTES

Administrative Assistantr

Re : Your Letter dated May 15, 2023 addressed to

CAPCO ET. AL., JANILA PAOLA CRUZ
Finding guilt for 1st OFFENSE and imposing the
Penalty of “WARNING”

Dear Ms. Callos,

This pertains to your letter dated May 15, 2023 addressed to CAPCO ET. AL., JANILA PAOLA
CRUZ, as owners of FIORI 115, and CARLO BONDOC, as Tenant of the same Fiori 115, CAPRI
OASIS PASIG CONDOMINIUM. I am writing in behalf of my clients, MA. CRISELDA C. CAPCO
and JANILA C. CAPCO, the actual registered owners of the said unit per the Condominium
Certificate of Title No. ___________.

Your letter has alarmed, and rightly so, my clients, not only for having violated their basic
constitutional right to due process, but more, for what appeared to be a question as to their
ownership of their unit and the existence of lease with another party, not known to them.
These matters should not be left uncorrected and unresolved and to ensure that their
interests are protected, my clients were compelled to engage my services. Since your letter
has exposed my clients to several legal claims, each item will be discussed hereunder, in the
sequence they arose from your letter.

1. CAPCO ET. AL., whom you named as owner together with one of my client, Janila
Cruz. First of all, please provide the names of all the other parties appearing as
owner of my clients’ unit which you have conveniently referred merely as ET. AL.,
Please provide us as well with a “duly authenticated” copy of Condominium
Certificate of Title or any other legal document which you used from your records as
reference, showing their ownership of the unit belonging to my clients ;

2. CARLO BONDOC whom you identified as tenant of my clients. We take the

assumption that your office exercised due diligence in your findings such that your
revelation that there is, in your records, an existing lease with this particular party
even amplified their concern about the security of their title of ownership. Please
provide us with a copy of the lease agreement in your records which you used as
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Unit 25-O Eastwood Parkview 2
Bgy. Bagumbayan, Quezon City 1110
arlyn.dimal@idloud.com
 Arlyn Dimal Pangan
reference in identifying the party-tenant. It is imperative that we identify how our
clients’ title to their unit has been altered and to cause the filing of the appropriate
civil and criminal cases, if warranted.

3. On finding the said named parties, together with my client, Janila Cruz, violating
Section 3.2 of your House Rules and Regulations and metted with the penalty of
WARNING

3.1 Respectfully, we take exception to your finding that my clients violated your
House Rules or any laws, rules and regulations for that matter and the
imposition of penalty to them, albeit seemingly light and causes no harm, was
illegal, in violation of my clients’ very basic constitutional right to due process.

In this regard, please provide us with your Rules of Procedure, the particular act
committed by my client Janila for which she was summarily found guilty and
metted with penalty, and the basis of the penalty imposed;

3.2 Nature of penalty with other parties. Your letter referred to a report submitted
to your office on that same day of May 15, 2023 that the named parties therein,
including my client, Janila, “were conducting business operation inside Cielo,
406, Capri Oasis”.(emphasis ours) The report contained nothing else but
seemed very serious and raised even more questions and created fear when it
was dispatched with such urgency. While my client Janila swore she has never
set foot inside Cielo 406 and does not know the other parties you found with
her, it still took a lot of energy and time before my other client, Janila’s mother,
could be pacified. She is unconvinced, exhausted and embarrassed by the talks
created by the incident, they consulted on their legal rights.

Your action finding my client violating House Rules and imposing a penalty therefor,
having been made without legal or factual basis, should be stricken down as illegal
and unlawful immediately within the next twenty four (24) hours from your receipt
hereof and my clients duly notified thereof in writing with a clear apology for the
damage it has caused them. Since your illegal action compelled my clients to engage
the services of counsel in this instance, demand is hereby made upon you to
reimburse them the amount of Twenty Five Thousand Pesos (P25,000.00) in legal
fees plus pay them the amount of Five Thousand Pesos (P5,000.00) in the form of
actual damages for their lost income for the two (2) days they had to attend to this
matter, within forty eight (48) hours from your receipt hereof.

Finally, please deliver the information and documents described in paragraphs 1, 2

and 3 hereof, update your records to indicate that my clients are the registered
owners of Fiori 115, duly notifying my clients thereof in writing, all within the same
period of forty eight (48) hours from your receipt hereof. Otherwise, we shall be

+639178277543
Unit 25-O Eastwood Parkview 2
Bgy. Bagumbayan, Quezon City 1110
arlyn.dimal@idloud.com
 Arlyn Dimal Pangan
constrained to file the necessary legal actions against you to protect my clients’
rights and interests which, if resorted to, will subject you to more expense.

I hope that you will give this request your usual immediate and favorable consideration.

Very truly yours,

Atty. ARLYN DIMAL PANGAN

Counsel for MA. CRISELDA C. CAPCO
and JANILA C. CAPCO

+639178277543
Unit 25-O Eastwood Parkview 2
Bgy. Bagumbayan, Quezon City 1110
arlyn.dimal@idloud.com