August 23, 2023

JERRY N. MAN
MIKE J. MAN
LEN C. MAN
130 J. Mariano Street, Catanduanes

Sirs:

In representation of our client, JUANA DELA CRUZ, this is to demand from

you the bringing out, production and release of the Transfer Certificate of Title (TCT)
No. C-16172 or to fully explain the reason for such failure if the same cannot be done.

Our client told us that the piece of lot with an area of 196 SQUARE METERS
and located at 130 J. Mariano Street, Balintawak, Caloocan City, evidenced by said
certificate with the structures therein standing is the only property left to her and
siblings Angelito, Reynaldo, Jesus, Manuel and Jane. You will recall that said
Certificate was issued in the name of your father, who died intestate on October 3,
1982 married to Nanoo-Man who recently died intestate on August 10, 2019. That all
siblings, except our client, Juana, reside on said property and would be prejudiced by
the loss or unlawful taking of said Certificate. Being so, Juana, Petra and Lanee, were
in unison in demanding from you the production of said Certificate. In said regard,
our client, Elena, with Manuel and Jane, has tendered their willingness to execute and
sign an Extrajudicial Settlement of Estate and/or Partition, once you produced said
Certificate. This is but fair to give and secure to everyone his rightful share of the
estate left by your deceased parents. From the moment of the death of your parents,
each of you, as the legal and mandatory heirs becomes an aliquot owner of the entire
property.

Unfortunately, said Certificate of Title is nowhere to be found as you have

colluded and conspired in its unlawful taking without the consent of Juana and your
other siblings, to their detriment. You will recall that said Certificate of Title was left
under your care by your mother, for safekeeping. Such fact has been attested by the
Barangay Tanod since a day before your mother was hospitalized, such fact was told
by your mother to her. That after the persistent pressures put on you, you admitted
that said title was truly entrusted to your care. However, you averred that it was no
longer in your possession as you have allegedly given said Certificate.

On the other hand, you denied having in your possession said title. You have
refused to speak amicably to settle the matter with your other siblings despite several

Demand Letter (Johanna S. Cayanan)

efforts exerted. You even refused to attend the invitation from the Barangay relative to
efforts to locate and bring out said Certificate or at least explain your side of the story.

And you, apparently have been covering the other siblings giving suspicion
that you have been in cahoots and conspiring with your said brothers, in the taking
and concealment of said Certificate.

You have no right to continuously take away and conceal said Certificate from
our client, who being an heir to your parents, likewise possesses an interest over the
property evidenced by said Certificate. Clearly, your action constitutes an outright
denial of the right our client to her due share in the estate of your parents, which
obtains from the moment of the death of your mother on March 10, 1985.

In this regard, undersigned advise you to take out the subject Certificate and or
if not possible, to render an explanation thereof. Afterwhich, you could concur and
voluntarily execute an “Extrajudicial Settlement of Property and/or Partition”. This is
to obviate the situation of a legal scuffle within you siblings and you facing a criminal
and/or civil action.

Failure to heed this demand within 10 days from receipt hereof, we would be
constrained to file a criminal case for Qualified Theft against you and other legal
action necessary to protect the interests of our client.

We hope that you will give this matter your utmost attention. This serves as a
final warning.

ATTY. MANDA L. PATASKY

Under my direction and consent:

JUANA DELA CRUZ

Demand Letter (Johanna S. Cayanan)