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Law Firm of

BACLIG & VILLANUEVA


Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
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Judge Vivencio A. Baclig (Ret.) Page | 1
Atty. Danny F. Villanueva, Ph.D.

23 April 2018

THE REGISTRAR OF DEEDS


Registry of Deeds, City of Makati

Re: Request for Registration/Annotation of Decision/Order/Etc.


On CCT No. 006-2011009504

Sir/Madam:

This refers to the above request of our client, Froilan Clemente,


Jr. relative to the above-stated CCT registered in his name. Copy of the
subject CCT is attached hereof for your reference.

Civil Case No. 14-641 filed before Branch 66 of the Regional Trial
Court of Makati City had already been dismissed by the said Court
under its Order dated ____________________, attached as Annex “B”
hereof.

The Order dismissing the case filed by Atty. Anita Chavez and
Sps. Maglalang had already attained finality. Copy of the certificate of
finality showing that the order of dismissal had already attained
finality is attached as Annex “C” hereof.

In view whereof, kindly REGISTER/ANNOTATE on CCT NO. 006-


2011009504 the Order of Dismissal and the Certificate of Finality
(Annexes “B” and “C” hereof) and based thereon TO CANCEL the
notices of adverse claim and lis pendens on the subject CCT.

We earnestly hope that you will act promptly and appropriately


on our above-stated request.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D. Page | 2
18 April 2018

ATTY. WILLIAM SIMOHON. MARIA ROSARIO OCHOA-MONTEJO


Mayor, Pulilan, Bulacan

Honorable Members of the Sangguniang Bayan:


Hon. Ricardo M. Candido
Hon. Enoc L. Santos, Jr.
Hon. Rolando S. Peralta
Hon. Renan B. Castillo
Hon. Rodolfo E. Arceo
Hon. Bernardino L. Santos
Hon. Reynaldo J. Clemente, Jr.
Hon. Lauro A. Valenzuela
Hon. Restituto T. Esguerra
Hon. Arman Tandoy

Hon. Sergio L. Sayo


OIC, Brgy. Chairman
Sto. Cristo, Pulilan, Bulacan

Re: Issuance/Release of Franchise To Open/Continue Operation of


RRS Cockfights Arena

Sirs/Madam:

This refers to the above matter referred to us by our client,


Roning R. Santos, of No. 813 Sto. Cristo, Pulilan, Bulacan, for the
taking of legal action.

Mr. Santos has already complied with all the legal requirements
for the renewal of the franchise of RRS Cockfights Arena and had paid
all the applicable fees and taxes and is willing to comply with whatever
requirement the Municipal Government would require yet up to this
time the application of our client has not been acted upon by your
good selves.

Your inaction and unexplained recalcitrance to grant the legal


and valid application of our client is akin to adding insult to injury in
the face of your swift issuance of business permit and license to
operate the following establishments: SM Prime Holdings, Inc., Meralco
Sub-station and Soldiers of Christ Healing Ministries, Inc.

In respect to SM Prime and Meralco Sub-station, the land


occupied by the said establishments has not been converted for
commercial and industrial purposes yet you allowed their operation.
As regards Soldiers of Christ, it has not been registered with the
Municipality yet you are allowing its operation and activities.

Please take note that your failure or neglect to perform your


duties in regard to the operation of SM Prime and Meralco sub-station
Page | 3
and your failure to require the said businesses the necessary ECC and
land conversion constitutes violations of RA 3019 and other provisions
of the Revised Penal Code.

The same goes with your obstinate refusal to act on the


application for renewal of franchise of RRS Cockfights Arena violates
section 3 of RA 3019 otherwise known as the Anti-Graft and Corrupt
Practices Act.

In view whereof, demand is hereby made for you to take


appropriate action on the just, valid and legal application for renewal
of franchise of RRS Cockfights Arena otherwise much to our regret we
shall take appropriate actions being contemplated by Mr. Santos
including filing of complaints before the Ombudsman involving the
operations of SM Prime, Meralco Sub-station and Soldiers of Christ
Healing Ministries and your inaction on the application of our client as
afore-stated.

We earnestly hope that you will act promptly and appropriately


on the matters presented in this letter.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
03 March 2018

HON. MARIA ROSARIO OCHOA-MONTEJO


Mayor, Pulilan, Bulacan

Honorable Members of the Sangguniang Bayan: Page | 4


Hon. Ricardo M. Candido
Hon. Enoc L. Santos, Jr.
Hon. Rolando S. Peralta
Hon. Renan B. Castillo
Hon. Rodolfo E. Arceo
Hon. Bernardino L. Santos
Hon. Reynaldo J. Clemente, Jr.
Hon. Lauro A. Valenzuela
Hon. Restituto T. Esguerra
Hon. Arman Tandoy

Hon. Sergio L. Sayo


OIC, Brgy. Chairman
Sto. Cristo, Pulilan, Bulacan

Re: Issuance/Release of Franchise To Open/Continue Operation of


RRS Cockfights Arena

Sirs/Madam:

This refers to the above matter referred to us by our client,


Roning R. Santos, of No. 813 Sto. Cristo, Pulilan, Bulacan, for the
taking of legal action.

Mr. Santos has already complied with all the legal requirements
for the renewal of the franchise of RRS Cockfights Arena and had paid
all the applicable fees and taxes and is willing to comply with whatever
requirement the Municipal Government would require yet up to this
time the application of our client has not been acted upon by your
good selves.

Your inaction and unexplained recalcitrance to grant the legal


and valid application of our client is akin to adding insult to injury in
the face of your swift issuance of business permit and license to
operate the following establishments: SM Prime Holdings, Inc., Meralco
Sub-station and Soldiers of Christ Healing Ministries, Inc.

In respect to SM Prime and Meralco Sub-station, the land


occupied by the said establishments has not been converted for
commercial and industrial purposes yet you allowed their operation.
As regards Soldiers of Christ, it has not been registered with the
Municipality yet you are allowing its operation and activities.
Please take note that your failure or neglect to perform your
duties in regard to the operation of SM Prime and Meralco sub-station
and your failure to require the said businesses the necessary ECC and
land conversion constitutes violations of RA 3019 and other provisions
of the Revised Penal Code.
Page | 5
The same goes with your obstinate refusal to act on the
application for renewal of franchise of RRS Cockfights Arena violates
section 3 of RA 3019 otherwise known as the Anti-Graft and Corrupt
Practices Act.

In view whereof, demand is hereby made for you to take


appropriate action on the just, valid and legal application for renewal
of franchise of RRS Cockfights Arena otherwise much to our regret we
shall take appropriate actions being contemplated by Mr. Santos
including filing of complaints before the Ombudsman involving the
operations of SM Prime, Meralco Sub-station and Soldiers of Christ
Healing Ministries and your inaction on the application of our client as
afore-stated.

We earnestly hope that you will act promptly and appropriately


on the matters presented in this letter.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D. Page | 6
03 March 2018

PURIFICACION S BUNING
Sto. Cristo, Pulilan
Bulacan

Re: Demand to Reimburse/Pay P659,530.40 plus Interest

Dear Ms. Buning:

This refers to the above demand of our client, Roning R. Santos,


of No. 813 Sto. Cristo, Pulilan, Bulacan which was referred to us for
legal action.

The above-stated amount represents the total amount paid by


our client for the real property taxes of Pulilan Octagon Coliseum for
the taxable years 2006-2015 as certified to by Municipal Treasurer
Leonora Del Rosario (please see attached Certification dated August
20, 2015) and further evidenced by Cashier’s Checks made payable to
the Municipal Treasurer of Pulilan, Bulacan.

The said real property taxes are supposed to be paid by you as


they are the obligations of the property owner, hence, you have the
obligation to reimburse the payment made by Mr. Santos to the
Municipal Treasurer of Pulilan, Bulacan plus the applicable legal
interest.

We earnestly hope that you will arrange payment of P659,583.40


plus legal interest to our client within five (5) days from receipt hereof
otherwise much to our regret we will be constrained to file appropriate
cases in court in order to recover the said amount for our client.

Yours truly,

DANNY F. VILLANUEVA
Page | 7

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
December 27, 2017

MR VIRGILIO G VICLAR
AZ-2 Brgy Aplaya Pila Laguna 4010

Re: Absence/Failure to Report to Work

Dear Mr Viclar

This refers to the above matter referred to us by Dae Yun


Construction Corporation

Based on Dae Yun’s record you had previously caused your co-
worker to “time-in” for you which is considered as a serious violation of
Dae Yun’s Company policy and your Employment Contract with the
said company

Last December 23 2017 after you submitted yourself for drug


testing in the morning you failed to report back to work in the
afternoon Today December 27 2017 you again failed to report for
work thereby causing undue injury to Dae Yun

We wish to point out to you that provision in your contract with


Dae Yun that says (1) x x x “Late/Unnoticed Absent may cause to the
termination of contract x x x” and (8) x x x “and on the Second Warning
will cause termination of this contract and No Compensation (13 th month
Pay) to receive”

In view whereof we urge you to report back to work immediately


so that you shall not be deemed to have abandoned your work and
explain why your afore-noted failure to report for work will not cause
the termination of your employment or this contract with Dae Yun
otherwise much to our regret we shall be constrained to apply the
afore-stated provisions by terminating your services in accordance
with existing laws jurisprudence
Your prompt action is earnestly urged

Yours truly,
Page | 8

DANNY F. VILLANUEVA

For future reference:

IAS PNP Camp Crame LBC No_______

Office of the Deputy Ombudsman LBC No_______


MOLEO Agham Rd Brgy Pinyahan
Quezon City

Office of the President LBC No________


Malacanang Manila

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
November 13, 2017

ENGR. ARCHIE _______________


Ollt Hilltop Construction
Assistant St., GSIS Villages
Project 8, Brgy. Bahay Toro, Q.C.

Re: Notice of Dishonor and To Pay Check No. WLK A


0000014094 dated June 30, 2017 for
P353,350 payable to ES Forms Builders & Supply
Dear Engr. Archie:

This refers to the above demand of our client, Es Forms Builders


& Supply for you to pay the amount represented by the above-
described check which you issued in payment of the scaffoldings Page | 9
supplied to you by our said client covered by delivery receipts, copies
of which are attached for your perusal and evaluation.

Our client expects and demands that you pay P343,350.00 which
is the amount due under the subject check plus interest and attorney’s
fee within five (5) days from receipt hereof, otherwise much to our
regret, we shall be constrained to sue you for Estafa and violation of
B.P. 22 by reason of your issuance of the subject check which was
dishonored by the drawee-bank, the same having been drawn against
an insufficient account.

We earnestly hope that you shall act accordingly and promptly.


Should we not hear from you up to November 22, 2017, we shall
proceed as afore-stated.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
November 13, 2017

ATTY. WALTER YOUNG


Cubao, Quezon City
Page | 10

Companero,

Warmest regards!

Kindly entrust to BERNARD DE GUZMAN the check or cash in


the amount of One Hundred Fifty Thousand Pesos (P150,000.00) by
way of refund of the partial payment for the agreed purchase of your
lots in Brgy. Silangan, San Mateo, Quezon City.

There is no way by which we can consummate the sale because


the lots are already in the names of the Santoses based on our
verification with the Municipal Assessor of San Mateo and the Registry
of Deeds of Marikina, Rizal.

If the refund is in the form of check please make it payable in


cash, crossed or for deposit only.

Any further queries or verification on the matter can be made


thru the following numbers: 364-5814 or 09276191033.

Yours sincerely,

DANNY F. VILLANUEVA

VIVENCIO S. BACLIG
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033 Page | 11
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
October 26, 2017
JUPITER E. MILA
Block 4, Lot 21
Tonsuya Letre, Caloocan City

Re: Demand to Account and Pay To Avoid Criminal


Case for Estafa and Imprisonment

Dear Mr. Mila:

This refers to the above matter referred to us by our client, Mr.


Froilan G. Clemente, Jr., for the filing of a criminal complaint for
Estafa against you over your purchase of that property situated in
Barangay Lancaan, Dasmarinas, Cavite, and now registered in your
name under TCT No. 057-2016022227 of the Registry of Deeds of
Cavite.

By reason of your (mis)representation and fraudulent claim that


you will pay the agreed selling price of the subject property through
housing loan with Pag-ibig Funds, our client had agreed to transfer the
ownership and title of the subject property in your name (see attached
TCT for your perusal and reference).

However, after the title to the property had been registered in


your name, you failed and refused to pay and/or to at least see our
client and account for the payment of the agreed price which resulted
to damage to him.

In view whereof, demand is hereby made for you to account


and/or pay the agreed price for your purchase of the subject property
within five (5) days from receipt hereof, otherwise, much to our regret,
we shall be constrained to file all appropriate cases in court including
criminal complaint for Estafa for which you may suffer imprisonment
for a period of at least twelve (12) years and to pay our client damages
in an amount to be fixed by the court.

Please act accordingly to avoid spending your days behind bars


of the prison house.

Yours truly,

DANNY F. VILLANUEVA
Cc: NBI, PNP

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman, Page | 12
Quezon City; Tel. Nos. 9204710; 0927-619-1033
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
October 17, 2017

THE HONORABLE CHIEF


BUREAU OF IMMIGRATION
Intramuros, Manila

Re: Request To Put JANET T. BOMBASE in the Look Out


and/or Watchlist Bulletin

Sir:

In the spirit of public service, our warmest greetings!

This refers to the above matter referred to us by our client, Mr.


Froilan G. Clemente, Jr., who is the complainant against Ms. Janet T.
Bombase in the case entitled People of the Philippines vs. Janet T.
Bombase, pending before Branch 39 of the Metropolitan Trial Court of
Quezon City, docketed as Criminal Case No. 16-01971-76-CR.

The above-stated case had been ordered archived pending the


arrest of accused Janet T. Bombase (copy of the Warrant of Arrest is
attached for your ready reference).

Mr. Clemente told us that Ms. Bombase is always out of the


Philippines reason why the warrant of arrest could not be successfully
served upon.

In view whereof, it is respectfully requested that Ms. Janet T.


Bombase be included either in the Look Out or Watch List Bulletin of
the Bureau so that the warrant for her arrest could be effected and the
case against her can proceed accordingly.

We express our heartfelt appreciation for your prompt and


positive action on our request.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman, Page | 13
Quezon City; Tel. Nos. 9204710; 0927-619-1033
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
December 1, 2017

THE HONORABLE ADMINISTRATOR


LAND REGISTRATION AUTHORITY
NIA Rd., Brgy. Pinyahan, Quezon City

Re: Consulta on Non-registration of Lis Pendens, TCT No. T-


77986, Registry of Deeds of Guiguinto, Bulacan (Primary Entry
No. 518604

Your Honor:

In the spirit of public service, our warmest greetings!

This refers to the above matter referred to us by Mr. Roning


Santos for the taking of appropriate legal action.

May we request certification pertaining to the Marriage License


allegedly issued to Victor Dumlao, Jr. on June 25, 1998. The copy of
the marriage contract forwarded to us by Mr. Victor Dumalo, Jr., our
client who intends to file an action for nullity of marriage is attached
for your perusal and reference.

As you can see, the copy forwarded to us is not clear, hence, we


could not indicate the exact number of the marriage license as well as
the name of the wife. Thus, we also request clear copy of the certificate
of marriage allegedly celebrated on June 26, 1998 in the Office of the
Mayor on the said date for purposes of submitting the same as a
documentary evidence for the Petition intended to be filed in the proper
Family Court.

The request for Certification as to whether your Good Office had


indeed issued a marriage license indicated in the Certificate of
Marriage as well as for issuance of a clear copy of the subject
certificate of Marriage shall be presented to you by our staff, MRS.
EVELYN UMALI DUMRIQUE who shall also pay the applicable fees for
the requested certification and copy of the certificate of Marriage.

We express our heartfelt appreciation for your prompt and


positive action on our request.
Yours truly,

DANNY F. VILLANUEVA
Page | 14
Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

Oct. 13, 2017

MR. LIU PENGFEI/ROMAI


No. 2608, Asiawealth Tower,
Leveriza St., Pasay City

Re: Demand to Pay P202,000.00 Interest and Damages

Sir:

This refers to the demand by our client, Carnavan Car


Rental Services, Inc., for the payment of car rental arrears in the
above-stated amount.

We strongly advise you to settle your obligations to our


client within five (5) days from receipt hereof otherwise much to
our regret, we shall be constrained to sue you in court in order to
collect the amount due to our client as well as make you liable for
interest, other expenses and damages pursuant to the car rental
agreement.

Thank you very much for your due attention and prompt
action on the matter.

Yours truly,
DANNY F. VILLANUEVA

Page | 15

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

Oct. 13, 2017

RUNE BERENTSEN
_____________________________
_____________________________

Re: Demand to Pay P411,100, Interest and Damages

Sir:

This refers to the demand by our client, Carnavan Car


Rental Services, Inc., for the payment of car rental arrears in the
above-stated amount.

We strongly advise you to settle your obligations to our


client within five (5) days from receipt hereof otherwise much to
our regret, we shall be constrained to sue you in court in order to
collect the amount due to our client as well as make you liable for
interest, other expenses and damages pursuant to the car rental
agreement.

Thank you very much for your due attention and prompt
action on the matter.

Yours truly,
DANNY F. VILLANUEVA

Page | 16

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

27 September 2017

THE HONORABLE CITY TREASURER


Quezon City Government, City Hall Complex

Re: Request for Issuance of Amended Certificate of Sale


and Final Bill of Sale covering Lot No. 1, Block No.
LRC PCS-78688 with an area: 5,869.00 sqm; Tax Dec. No. E-097-
97655, Property Index No. 19-097-35-002 sold at the public
auction on October 9, 2008

Sir/Madam:

Warmest regards!

This pertains to the above-stated request of our client, Froilan G.


Clemente, Jr., of Quezon City, to reflect the fact that the property he
bought in the Property Tax Delinquency Sale conducted on October 9,
2008 REFERS and PERTAINS to the property registered in the name of
Cathay Metal Corporation embraced by TCT No. RT-63521 (254919),
copy attached hereof.

The subject property is covered by Tax Declaration of Real


property TD/ARP No. E-097-09803 0002-2011-02-000208-9064 under
Property Index 19-097-35-002 in the name of Sagrario Carlos with an
area of 5,869.00, hence, both the Certificate of Sale and the Bill of
Final Sale that was issued to Mr. Clemente reflect this information.

However, when Mr. Clemente checked and verified the


information with the Office of the City Assessor, the said Office issued
a Certification dated July 27, 2012 (copy attached for your reference)
stating that “NO TAX DECLARATION WAS ISSUED UNDER THE TCT
NO. RT-63521 (254919) in the name of Cathay Metal Corporation.
Only the preceding TCT No. 207280 has tax declaration which
bears the same lot number and description such as PIN 114-19-
097-35-002, Lot 1 (LRC) PCS-78688.”

It is very clear from the above that the property covered by the
Page | 17
Certificate of Sale and the Final Bill of Sale issued by your Honorable
Office in favor of Mr. Froilan Clemente, Jr. IS THE PROPERTY
COVERED BY TCT NO. RT-63521 (254919) IN THE NAME OF CATHAY
METAL CORPORATION (Copy attached).

In view whereof, it is respectfully requested that an amended


Certificate of Sale and Final Bill of Sale be issued to Mr. Froilan G.
Clemente, Jr. reflecting the afore-stated fact to conform with the
certification issued by the City Assessors Office.

Your prompt action on this humble request will be duly


appreciated.

Yours sincerely,

DANNY F. VILLANUEVA
Page | 18

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
August 31, 2017

ANNA MARIE PENA


No. 187, Bustos, Bulacan

Dear Ms. Pena:

Warm greetings!

We write in behalf of our client, OCTAGON METAL SCRAPS


represented by Mr. Jed Maloto, regarding the pull-out of its trucks
with Plate Nos. NTU-172 and UGG-868 as well as the following
equipment, tools and materials: 48 Tanks, Oxygen Cylinder; 6 11/kg
LPG Cylinders and 3 LPG Cyl/Tanks, in view of the termination of its
contract with your company.

Our client had already suffered so much damages by reason of


the unjustified holding and/or detention of the afore-stated properties
of our client, hence, we will appreciate very much if you can arrange
for their expeditious release.

We will wait for your notice within five (5) days from receipt
hereof so that we will withhold court action to recover the same
through the court.

Yours truly,

DANNY F. VILLANUEVA
Page | 19

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
August 15, 2017

F.F. CRUZ & CO., INC.


No. 800 EDSA, Quezon City

Attn: MR. VIC CARRABACAN


BAC Chairman

Sir:

Warm greetings!

We write in behalf of our client, OCTAGON METAL SCRAPS


represented by Mr. Jed Maloto, regarding the pull-out of its
trucks with Plate Nos. NTU-172 and UGG-868 as well as the
following equipment, tools and materials: 48 Tanks, Oxygen
Cylinder; 6 11/kg LPG Cylinders and 3 LPG Cyl/Tanks, in view of
the termination of its contract with your company.

Our client had already suffered so much damages by reason


of the unjustified holding and/or detention of the afore-stated
properties of our client, hence, we will appreciate very much if
you can arrange for their expeditious release.

We will wait for your notice within five (5) days from receipt
hereof so that we will withhold court action to recover the same
through the court.

Yours truly,
DANNY F. VILLANUEVA

Page | 20

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
August 15, 2017

REX/VIVIAN PAPA
Lot 33, Block 5, Fairview

Re: Demand to Return/Account Three (3) Long Spa GI Sheets


and Three (3) GI Gutter

Dear Mr. Rex and Ms. Vivian Papa:

We write in behalf of our client, Maria Delma Dinogan of No. 319 Ma.
Martha St., Dona Carmen Subd., Brgy. Commonwealth, Quezon City,
regarding your felonious and criminal act of stealing and/or causing the
taking and transportation of Three (3) Long Span GI sheets and Three (3) GI
Gutter from her above-stated premises presumptively for your personal use
as you did not seek her permission or consent before you took and/or have
taken and transported out of our client’s premises her above-stated
construction materials.

In view whereof, DEMAND is hereby made for you to RETURN and/or


ACCOUNT the afore-stated construction materials within five (5) days from
receipt hereof otherwise much to our regret we shall be constrained TO
IMMEDIATELY FILE CRIMINAL CHARGES including the charge for
QUALIFIED THEFT AND/OR ESTAFA against you before the City Prosecutor
of Quezon City in order to bring you before the bar of justice where you can
be imprisoned for committing the afore-stated crimes.

Moreover, this also serves as our final demand for you to comply with
your agreement, undertaking and commitment to do the roofing, ceiling and
other related works in the house of our said client in accordance with your
representation, quotation, bill of materials and the industry standards.
Should you fail to fulfill your contractual obligations we shall be constrained
also to sue you to collect the P500,000.00 paid by our client to you plus
damages.
Your immediate compliance is a must if you want to avoid
imprisonment and the hassle of court action.

Yours truly,
Page | 21

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
August 14, 2017

Philippine Deposit Insurance Corporation


5th Floor, SSS Building
Ayala Ave. cor. V.A. Rufino St.
Makati City, Metro Manila

Re: Levy (Civil Case No. Q-35287, RTC, Q.C.); G.R. No. L-
94796
TCT Nos. RT 112347 (303898)- Lot 6, Blk. 1;
RT 112346 (303887)- Lot 10, Blk. 3
RT 112326 (303897)-Lot 8, Blk. 2;
RT 112325 (303896)-Lot 6, Blk. 2;
RT 112324 (303889)-Lot 14, Blk. 3;
RT 113023 (303888)-Lot 13, Blk. 9

Sir/Madam:

We write in behalf of our client (pls. refer to attached aauthorization),


Norma C. Espinosa, of No. 7 Irwin St., Filinvest 2, Quezon City, the
registered owner of the above-stated lots.

According to our client, the judgment obligations of the subject lots in


favor of defunct Peso Bank had been assigned to PDIC, hence, this letter.

May we request an official discounted computation of the judgment


debt encumbering the subject lots so that we can make the necessary and
appropriate action to settle the same.

Your kind and prompt action on our request will be highly


appreciated.

Yours truly,
DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman, Page | 22
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
August 4, 2017

LUCILA M. FAJARDO
No. 10, El Salvador St.
Betterliving Subd.
Paranaque City

Re: Placing under Alarm or as hot car the following motor


vehicle: Make/Type: Toyota 4x2 Fortuner, 2016
Engine No. 2KDS584815; Chassis No.
MHFZR69G203136620; Plate No. CS#YT 4547
Color: Silver Metallic
DEMAND TO ACCOUNT AND/OR RETURN P900,000.00

Dear Ms. Fajardo:

This pertains to the above-stated matter referred to us by our client,


Rosell C. Gamera of Brgy. Osmena Culion, Palawan, for the taking of all
appropriate legal action over your false, baseless and felonious action of
reporting the above-described car of our client as subject of “carnapping”
and/or of theft by a certain Dionesio Cadano.

Madam, you sold the subject car to our client for P900,000.00 under a
Deed of Sale of Motor Vehicle dated February 20, 2017 (see attached copy for
your reference).

It appears that despite your sale of the subject car to our client, you
made it appear that you executed an SPA in favor of one Jeffrey Salonga who
pretended to represent you in filing a malicious and false statement and
report that the subject car was the subject of carnapping and/or theft by a
certain Mr. Cadano.

In view whereof, WE DEMAND THAT YOU WITHDRAW YOUR


COMPLAINT BEFORE THE HPG, PNP and/or the placing of our client’s car
under nation-wide alarm and/or RETURN/REFUND the P900,000 that our
client had paid for the subject car, otherwise, much to our regret we shall
sue you for falsification of public documents, for Perjury and for damages
before proper courts as your felonious and baseless actions had caused so
much damage and prejudice to our client.

We earnestly hope that you shall act accordingly and promptly. Should
we not hear from you up to August 10, 2017, we shall proceed as afore-
stated.

Yours truly,
DANNY F. VILLANUEVA

Page | 23

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
August 4, 2017

JEFFREY V. SALONGA
MELEA-GEOFF TRANSPORT SERVICE
No. 8288 Dapitan St., Guadalupe Nuevo,
Makati City

Re: Placing under Alarm or as hot car the following motor


vehicle: Make/Type: Toyota 4x2 Fortuner, 2016
Engine No. 2KDS584815; Chassis No.
MHFZR69G203136620; Plate No. CS#YT 4547
Color: Silver Metallic
DEMAND TO ACCOUNT AND/OR RETURN P900,000.00

Dear Mr. Salonga:

This pertains to the above-stated matter referred to us by our client,


Rosell C. Gamera of Brgy. Osmena Culion, Palawan, for the taking of all
appropriate legal action over your false, baseless and felonious action of
reporting the above-described car of our client as subject of “carnapping”
and/or of theft by a certain Dionesio Cadano.
The above-described car is registered in the name of our client and she
bought it regularly and validly from the car’s registered owner, LUCILA M.
FAJARDO, under a Deed of Sale of Motor Vehicle dated February 20, 2017
(see attached copy for your reference).
It appears that you executed a false affidavit by pretending that you
were appointed by Ms. Fajardo as attorney-in-fact in relation to the subject
car and in filing a complaint before the HPG of the PNP when in truth and in
fact the SPA dated June 8, 2017 is a falsified document as Ms. Fajardo has
not signed any of such SPA.
For your information, our client was able to confirm from Ms. Fajardo
and that she herself had signed the deed of sale through Mr. Gabriel
Fernandez of Brgy. North Fairview, Quezon City.
In view whereof, WE DEMAND THAT YOU WITHDRAW YOUR
COMPLAINT BEFORE THE HPG, PNP and/or the placing of our client’s car
under alarm otherwise much to our regret we shall sue you for falsification
of public documents, for Perjury and for damages before proper courts as
your felonious and baseless actions had caused so much damage and
prejudice to our client.
We earnestly hope that you shall act accordingly and promptly. Should
we not hear from you up to August 10, 2017, we shall proceed as afore-
stated.

Yours truly,
Page | 24

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
August 4, 2017

GABRIEL FERNANDEZ
Block 71, Lot 7A
North Fairview Subdivision
Brgy. North Fairview, Quezon City

Re: Your Sale to Rosell Gamera of the following motor


vehicle: Make/Type: Toyota 4x2 Fortuner, 2016 Model
Engine No. 2KDS584815
Chassis No. MHFZR69G203136620
Plate No. CS#YT 4547
Color: Silver Metallic
DEMAND TO ACCOUNT AND/OR RETURN P900,000.00

Dear Mr. Fernandez:

This pertains to the above-stated matter referred to us by our client,


Rosell C. Gamera of Brgy. Osmena Culion, Palawan, for the taking of all
appropriate legal action over your felonious, unlawful and fraudulent act of
selling a “carnap” and/or stolen vehicle to our said client for P900,000 under
a forged and/or falsified Deed of Sale of Motor Vehicle dated February 20,
2017.

The HPG of the PNP in Camp Crame has issued a certification dated
July 11, 2017 (see attached copy for your reference) stating that the above-
described car that you sold to our client is the subject of a nation-wide
alarm, the car being the subject of a “carnapping”, hence, you have no right
at all to sell the subject car to our client and to receive from our client the
P900,000.00 that you demanded as price thereof.

In view of all the foregoing, demand is hereby made of you to account


for and to return/refund and/or give back to our client the P900,000.00 she
paid you pursuant to the afore-stated fraudulent sale otherwise we shall be
constrained to institute all appropriate legal actions against you including
the filing of criminal cases for carnapping and/or Estafa and falsification
and use of falsified documents in order to fully protect the rights of our
client.

We earnestly hope that you shall act accordingly and promptly. Should
we not hear from you up to August 10, 2017, we shall proceed as afore-
stated.
Page | 25
Yours truly,

DANNY F. VILLANUEVA

r failure shall

Letter dated July 4, 2017

Dear Mr. Dela Cruz:

Warmest regards!

We write in behalf of our clients, Evelvie Gabina and Joan


Arbis of No. 282 Sitio Igiban, Brgy. Sta. Cruz, Antipolo City
regarding your threat to demolish their houses at their afore-
stated address.

You know the law and that you are being forewarned not to
place the law in your hands lest you will commit the crime of
coercion and trespassing.

We shall certainly file all appropriate criminal actions


against you if you will intrude, usurp and demolish the houses of
our client without and not in accordance with a court order or
writ of execution issued by the Court.

Please be guided accordingly. Any communications intended


to our clients should be coursed through us.

We look forward to meeting you personally to discuss


amicably our common concerns.

Yours truly,

DANNY F. VILLANUEVA
Page | 26

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
July 26, 2017

ATTY. ERNESTO A. TABUJARA


Tabujara & Associates Law Offices
2nd Flr., Miladay Center, 150 Jupiter St.
Bel-Air, Makati City 1209, Philippines

Re: Your Letter dated July 22, 2005

Companero:

Warmest regards!

May we know if you still represent and/or are still acting for
Mark Dayrit and/or Tala Royal Highlands Corporation who
bought from our clients, Heirs of Zacarias and Ma. Ramos vda. de
Robles that parcel of land situated at Tala, Orani Bataan covered
by OCT No. 341?

We were requested by the said Heirs to communicate with


you if Mr. Dayrit is still interested to proceed with the sale, if not,
they are now ready to refund the earnest money paid by Mr.
Dayrit in the amount of P3,700,426.25.

Moreover, our clients are very eager to discuss the matter


with your client on any date and place convenient to you.
We look forward to meeting you and your client. Best
regards.

Yours truly,
Page | 27

DANNY F. VILLANUEVA

Re: Letter dated April 11, 2017 regarding Own


Damage Claim & Required Owner’s Participation

Dear Mr. Sy:

Our warmest greetings!


We write in behalf of our client, JOSERRY B. LLUBIT of No. 44
Bush St., Freedom Park 4, Batasan Hills, Quezon City regarding the
above matter for the taking of IMMEDIATE LEGAL ACTION.

Based on your letter dated April 11, 2017, you are requiring our
client to pay P19,333.29 as his total participation in the repair of his
insured motorcycle.

Requiring our client to pay the above-stated amount is in


violation of your obligation as insurer, hence, we have advised our
client against giving conformity to your proposal. By way of counter-
offer, we propose P5,000.00 as our client’s participation. We believe
that the amount is reasonable considering the overall expenses
involved in the repair of our client’s motorcycle.

In view whereof, we demand that you immediately cause the


release and delivery of the repaired motorcycle to our client within five
(5) days from receipt hereof and we shall make a check in the amount
of P5,000.00 available payable to Wheeltek Bigbites or to you.

We expect immediate reply from you or compliance with this


demand otherwise we shall institute appropriate action to enforce our
client’s right as insured and hold you liable for the damages he
sustained by reason of your neglect and unreasonable action.

Yours truly,
DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033 Page | 28
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
July 25, 2017

THE HONORABLE CLERK OF COURT


Branch 162, Regional Trial Court of Pasig City
With Station in San Juan

Sir/Madam:

The undersigned is the counsel of record for plaintiff Froilan G.


Clemente, Jr. in his case against Sps. Ariel and Annalyn Manalo,
docketed as Civil Case No. R-QZN-15-06511-CV pending before
Branch 92 of the Regional Trial Court of Quezon City.

The said RTC-QC, has directed the plaintiff to submit “authentic”


(Please see attached copy of the Order dated July 6, 2017) or certified
true copies of the following documents: Decision dated ___________,
Entry of Judgment dated ____________, and Decree of Separation of
Properties dated ______________, rendered and issued in connection
with JDRC Case No. ________________ between the said Sps. Manalo.

In view whereof, we request the issuance of certified true copies


of the above-stated documents. Our staff, Charies Domingo, will
present this request and pay the applicable fees for the requested
documents.

As ever, we express our heartfelt appreciation for your prompt


and positive action on our request.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman, Page | 29
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

July 24, 2017

RODEL ALVEYRA and all persons


Claiming and deriving rights from and under him
Block 5, Lot 12, Del Monte Heights,
Kaypian, City of San Jose Del Monte
Bulacan,

Re: Demand To Vacate that lot covered by TCT No. 040-


2014028349 of the Registry of Deeds of Bulacan, Meycauyan Branch

Sirs/Mesdames:

In the spirit of peace and brotherly love, our warmest greetings!

This refers to the above matter referred to us for legal action by


Michelle, Alejandro, Mark Ferdinand and Remedios, all surnamed
Pasion, through their mother acting as attorney-in-fact, Ma. Theresa
Pasion, of B1-A, Lot 11 Jeremiah St., Cielito Homes, Caloocan City.

You are occupying the above-described lot of our client illegally


and without their knowledge and consent, hence, this demand for you
to peacefully vacate the same within ten (10) days from receipt hereof.
Should you fail or refuse to heed the just and valid demand of our
client, much to our regret, we shall be constrained to institute
appropriate action in court to recover its possession from you.

We will appreciate very much your prompt and appropriate


action on the matter so that we shall all be spared from the
unnecessary rigors and expense appurtenant to court actions.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman, Page | 30
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
July 17, 2017
THE REGISTRAR
Registry of Deeds of Quezon City
East Avenue, Diliman, Quezon City

Re: Implementation of the Decision dated May 18,


2017 rendered by Branch 81, RTC-Q.C. in
LRC Case No. R-QZN-16-11224-LR

Sir/Madam:

In the spirit of public service, our warmest greetings!

It appears that you refuse to issue the second owner’s copy of


TCT No. (-262266) PR-31468 despite the finality of the decision
rendered by Branch 81 of the Regional Trial Court of Quezon City in
LRC Case No. R-QZN-16-11224-LR for the reason that the registration
of the subject title in your Registry is provisional only.

To remedy the situation, we filed the necessary Manifestation


and Motion in Court (please see attached copy), but the Honorable
Court under its Order dated July 5, 2017 (attached for your perusal
and reference) refused to act on the Motion as the same is a new
matter that the Court can no longer entertain considering that the
Decision has become final and executor.

It is our humble submission that the Decision, the Certificate of


Finality and the Order dated July 5, 2017 are sufficient as basis for
your Office to implement the Decision of the Court directing the
issuance of second owner’s copy of TCT No. 262266/PR-31468. We
know of no legal basis for the Registry of Deeds to refuse or not to
implement the afore-stated final decision of the Court. If there is such
a basis, it is our humble submission that the petitioner is entitled to a
formal ruling so that we can act accordingly or take the necessary
action or representation in court to amend and/or correct its Decision
that would include the making of the provisional registration
permanent.

As ever, we express our heartfelt appreciation for your prompt


and positive action on our request.

Yours truly,
DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman, Page | 31
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
June 8, 2017

THE SSS/BIR

Re: Request for SSS/TIN Number of EVELYN


MIRANDA y LEANO

Sir/Madam:

Warmest greetings!

We are writing you in behalf of our client, Froilan G.


Clemente, Jr. regarding the above matter in order for us to
comply with the requirements of BPI Bank relative to the
execution of court judgment against Evelyn L. Miranda.

For your perusal, we are attaching copy of the letter sent by


BPI as well as the Writ of Execution and Garnishment issued by
the Regional Trial Court of Quezon City.

We earnestly hope that our above request will merit your


immediate and appropriate action.

Thank you.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman, Page | 32
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
April 29, 2017
HENRY D. MANIQUIS
MARIETTA I. MANIQUIS
MA. TERESA F. EVANGELISTA
Brgy. Sibul, San Miguel, Bulacan

Re: Demand to Account for the various amounts of money


received and/or the 3-hectare land sold to Dr. Ariado

Gentleman/Ladies:

Our warmest greetings!

We write in behalf of our client, Dr. Artonie Ariado, regarding the


above matter for the taking of IMMEDIATE LEGAL ACTION.
According to our client, you represented to him that you were
authorized to sell a 3-hectare parcel of land belonging to a certain Guillermo
Teppang, situated at Sitio Cogonan, Brgy. Sibul, San Miguel, Bulacan, and
that on various occasions you gypped our said client into delivering the
following amounts of money:

March 16, 2015---P200,000;


August 30, 2015—P300,000;
Jan. 20, 2016-- P720,000

Per your representation, the above-stated amounts shall be used in


processing the title to the subject property and the transfer thereof to Dr.
Ariado but up to this time, nothing happened, and you have not shown and
surrendered any document that would at lease prove that the money of our
client have been truly used to their intended purposes.

In view whereof, FINAL DEMAND is hereby made for you to account


BY RETURNING the money of our client AND/OR TURN OVER THE
DOCUMENTS THAT WOULD SHOW THAT THE LAND EXIST and that the
title thereof has been duly registered in our client’s name within five (5) days
from receipt hereof, otherwise, much to our regret we shall be constrained
TO IMMEDIATELY FILE CRIMINAL CHARGES including the charge for
ESTAFA against you before the City Prosecutor of Quezon City in order to
bring you before the bar of justice where you can be imprisoned for
committing the afore-stated crime of Estafa.

Your immediate compliance is a must if you want to avoid


imprisonment and the hassle of court action.
Yours truly,

DANNY F. VILLANUEVA

Page | 33
Re: Letter dated April 11, 2017 regarding Own
Damage Claim & Required Owner’s Participation

Dear Mr. Sy:

Our warmest greetings!


We write in behalf of our client, JOSERRY B. LLUBIT of No. 44
Bush St., Freedom Park 4, Batasan Hills, Quezon City regarding the
above matter for the taking of IMMEDIATE LEGAL ACTION.

Based on your letter dated April 11, 2017, you are requiring our
client to pay P19,333.29 as his total participation in the repair of his
insured motorcycle.

Requiring our client to pay the above-stated amount is in


violation of your obligation as insurer, hence, we have advised our
client against giving conformity to your proposal. By way of counter-
offer, we propose P5,000.00 as our client’s participation. We believe
that the amount is reasonable considering the overall expenses
involved in the repair of our client’s motorcycle.

In view whereof, we demand that you immediately cause the


release and delivery of the repaired motorcycle to our client within five
(5) days from receipt hereof and we shall make a check in the amount
of P5,000.00 available payable to Wheeltek Bigbites or to you.

We expect immediate reply from you or compliance with this


demand otherwise we shall institute appropriate action to enforce our
client’s right as insured and hold you liable for the damages he
sustained by reason of your neglect and unreasonable action.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
May 29, 2017

ENRIQUE B. SY
Senior Manager-Claims
Paramount Life & General Insurance Corporation
14th & 15th Flr., Sage House,110 V.A. Rufino St., Page | 34
Legaspi Village, Makati City, 1229

Re: Letter dated April 11, 2017 regarding Own


Damage Claim & Required Owner’s Participation

Dear Mr. Sy:

Our warmest greetings!


We write in behalf of our client, JOSERRY B. LLUBIT of No. 44
Bush St., Freedom Park 4, Batasan Hills, Quezon City regarding the
above matter for the taking of IMMEDIATE LEGAL ACTION.

Based on your letter dated April 11, 2017, you are requiring our
client to pay P19,333.29 as his total participation in the repair of his
insured motorcycle.

Requiring our client to pay the above-stated amount is in


violation of your obligation as insurer, hence, we have advised our
client against giving conformity to your proposal. By way of counter-
offer, we propose P5,000.00 as our client’s participation. We believe
that the amount is reasonable considering the overall expenses
involved in the repair of our client’s motorcycle.

In view whereof, we demand that you immediately cause the


release and delivery of the repaired motorcycle to our client within five
(5) days from receipt hereof and we shall make a check in the amount
of P5,000.00 available payable to Wheeltek Bigbites or to you.

We expect immediate reply from you or compliance with this


demand otherwise we shall institute appropriate action to enforce our
client’s right as insured and hold you liable for the damages he
sustained by reason of your neglect and unreasonable action.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
May 29, 2017
Page | 35
CORAZON LIBRIA SABULAO
Brgy. Pago, Tanauan, Leyte

Re: Demand to Account for the various jewelry items


and/or the sale proceeds thereof

Dear Ms. Sabulao:

Our warmest greetings!

We write in behalf of our client, Jinabelle F. Villanueva of No. 11


Pajo St., Project 2, Quirino 2-A, Quezon City, regarding the above
matter for the taking of IMMEDIATE LEGAL ACTION.

According to our client, she entrusted to you several jewelry


items to be sold by you under the specific trust that should the
jewelries be not sold, you are under obligation TO RETURN THE SAME
and should the jewelries be sold, you are TO ACCOUNT FOR THE
PROCEEDS of the sale minus your commission.

It appears that despite previous demands, you failed and refused


and you continue to fail and refuse TO ACCOUNT FOR THE
JEWELRIES and/or THE PROCEEDS thereof in accordance with the
said arrangement the total amount of P53,545.

In view whereof, we require you to make the necessary


accounting by returning the jewelries or to turn over the proceeds of
the sale to our client within five (5) days from receipt hereof, otherwise,
much to our regret we shall be constrained TO IMMEDIATELY FILE
CRIMINAL CHARGES including the charge for ESTAFA against you
before the City Prosecutor of Quezon City in order to bring you before
the bar of justice where you can be imprisoned for committing the
afore-stated crime of Estafa.

Your immediate compliance is a must if you want to avoid


imprisonment and the hassle of court action.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman, Page | 36
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
May 26, 2017

RICHARD S. CHUATECO and/or


HARVARD MULTILAND REALTY CORP.
B2L14, Montville Place-Selecta
Balintawak, Quezon City

Sir:

Our warmest greetings!

We write in behalf of our client, Aristhel C. Calapardo, of No. 907


La Mesa Drive Dona Nicasia Puyat Subd., Brgy. Commonwealth,
Quezon City, regarding the following documents: Joint Venture
Agreement dated October 24, 2015 and Contract To Sell over that 551
square meter lot located at Dona Nicasia Puyat Subdivision, Brgy.
Commonwealth, Quezon City for the filing of appropriate legal action
such as for reformation of instruments and/or for rescission of
contracts.

Before bringing the matters to court, our client wants to clarify


certain issues about the terms of the joint venture and the contract to
sell and how and when the same shall be enforced.

We will highly appreciate if you will agree on a meeting on a date


and place convenient to you or you may come to our Office during
office hours on any day during weekdays. You may also reach us
through our phones and e-mail address.

Your indispensable cooperation will be most welcome.

Yours truly,
DANNY F. VILLANUEVA

Page | 37

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
May 15, 2017

THE REGISTRAR
Registry of Deeds of Quezon City
East Avenue, Diliman, Quezon City

Re: Request for Cancellation/Withdrawal of


Consulta, etc. on TCT Nos. 004-2017005238
(T-342964) (PR-43396); 004-2017005239 (T-
342958) (PR-43395)
Sir/Madam:

In the spirit of public service, our warmest greetings!


The Decision dated September 26, 2016, among others, orders
the Registry of Deeds TO RELEASE and/or FREE the New Certificates
of Title in the name of the plaintiff from hold/safekeeping/pending
transaction status and allow the registration of the transaction status
and allow the registration of the transaction that may be entered into
by the parties x x x.
It appears that a consulta involving the subject transfer
certificates of title had been made before the LRA which is contrary to
the decision and order of the Court to reinstate the transfer certificates
of title in the name of Mover Enterprises, Inc. free from liens and
encumbrances.
In view whereof, it is respectfully requested that the consulta
pending before the LRA involving the subject transfer certificates of
title be cancelled and/or withdrawn in compliance with the Order of
the Regional Trial Court of Quezon City.
As ever, we express our heartfelt appreciation for your prompt
and positive action on our request.
Yours truly,

VIVENCIO S. BACLIG

Page | 38

LUIS I. MIJARES

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 364-5814; 0927-619-1033; E-mail: dannyvillanuevalaw@gmail.com
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
April 20, 2017

AUREA B. BONDOC
MARCELA B. BONDOC
L8, Blk 49, Ph3, Pampano St.
Longos, Malabon City

Re: Demand To Partition the following properties: Parcel of


land situated at Bagong Barrio, Pandi, Bulacan covered by TCT No. T-
204577; lot situated at Grace Park, Caloocan City covered by TCT No. C-
322953; 4 Lots and improvements located at Blk. 49, Lots 8 & 9,
Pampano St., Longos. Malabon City, covered by TDs B-011-13828; B-
011-15792& B-011-15795

Mesdames:

Our warmest greetings!

We represent your brother, Rogelio B. Bondoc, and his appointed


atty.-in-fact, Roning Santos, thus, we send this letter regarding their
above-stated demand to partition the above-described lots and/or to
extra-judicially settle the Estate of your deceased parents, Juan
Bondoc and Mercedes B. Bondoc, as well as that of your deceased
sister, Felicidad B. Bondoc.
As your full-blood brother, Rogelio Bondoc is entitled to get one-
third (1/3) portion of the subject lots. Rogelio is in immediate and dire
need of money for his hospitalization as he has been diagnosed to be
suffering from stage 3 Lung Cancer.
Page | 39
The settlement of estate and/or partition of inherited properties
is being mandated by law and any co-heir may demand any time to
partition the subject properties and the same may not be refused as
the right of Rogelio over his shares in the subject properties had
already accrued and became vested at the moment of death of your
parents and sister, Felicidad Bondoc.

In view whereof, as part of Rogelio’s earnest efforts to avoid court


action, although for several times you had refused his verbal demands
for the delivery of his shares, we earnestly urge you to agree and
cooperate on an extra-judicial settlement of estate and/or partition of
the subject properties in order to avoid unnecessary expenses on
litigation and the hassles concomitant thereto.

We will highly appreciate if you will agree on a meeting on a date


and place convenient to you or you may come to our Office during
office hours on any day during weekdays. You may also reach us
through our phones and e-mail address.

Your indispensable cooperation will be most welcome.

Yours truly,

DANNY F. VILLANUEVA
Page | 40

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
April 20, 2017

MR. SANTIAGUEL
ERJOHN TRANSIT
Erjohn & Almarl Transit Corp.
Silang Main Office & Garage
Km. 46 Aguinaldo Highway
Lalaan 1st, Silang, Cavite

Re: Demand To Pay 1.5M plus interest


(Asiatrust Bank Checks)

Sir/Madam:

Our warmest greetings!

This refers to the above matter referred to us for legal action by


our clients, the Heirs of the late Aquilino Camaclang and Mr. Zaldy
Mateo of Makati City.

Our said clients told us that up to this date you refused and
failed and continue to refuse and fail to pay the balance in the amount
of One Million and Five Hundred Thousand Pesos (P1,500,000.00)
representing the price for the lot you purchased from our said clients
because you ordered your bank to stop the payment of the checks you
issued to them.

In view whereof, demand is hereby made for you to pay the


above-stated amount within five (5) days from receipt hereof. Should
you refuse and fail to heed the just and valid demand of our client,
Page | 41
much to our regret, we shall be constrained to institute appropriate
legal actions against you to recover what is due our client as above-
discussed.

We strongly and earnestly recommend that you settle the just


and valid demands of our client in order for us to be spared from the
hassles and unnecessary expense that come with protracted
litigations.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

April 20, 2017

HON. JOSE B. LORIEGA, JR.


Registrar of Deeds
Registry of Deeds, Antipolo City

Re: Request for Certified Electronic Copy


Of OCT No. 114, Free Patent No. V23191
In the name of Antenor S. Virata

Sir:

In the spirit of public service, our warmest greetings!

Kindly issue us certified electronic copy or certified true copy


of the above-described certificate of title if one is on file and a
certification to the effect that it has no record if such is the fact
per the record in your Registry.

As ever, we express our heartfelt appreciation for your


prompt and positive action on our request. Page | 42

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

April 20, 2017

RENA ROSE IGDONES


And all persons claiming
And deriving rights from and under her
Sumulong Highway, Circumferential Rd.,
Brgy. San Isidro, Antipolo City

Re: Demand To Vacate that lot covered by OCT No. 36,


registered in the name of Tomas Inabayan, Registry of
Deeds of Antipolo City (Copy attached for Reference)

Dear Madam:

In the spirit of peace and brotherly love, our warmest greetings!

This refers to the above matter referred to us for legal action by


the Heirs of Tomas Inabayan of Circumferential Rd., Antipolo City.
You are occupying the above-described lot of our client illegally,
hence, this demand for you to peacefully vacate the same within ten
(10) days from receipt hereof. Should you fail or refuse to heed the just
and valid demand of our client, much to our regret, we shall be
constrained to institute appropriate action in court to recover its
possession from you.
Page | 43

We will appreciate very much your prompt and appropriate


action on the matter so that we shall all be spared from the
unnecessary rigors and expense appurtenant to court actions.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

April 19, 2017

ADOR SARINAS
Block 66, Lot No. 26
Yen St., North Fairview, Quezon City

Re: Demand To Vacate Block 66, Lot 26, Yen St., North
Fairview, Quezon City, covered by TCT No. 36313, RD of Quezon City

Dear Sir:

In the spirit of peace and brotherly love, our warmest greetings!

This refers to the above matter referred to us for legal action by


Ms. Rosalie R. Chavez of No. 11-B Impala st., Greater Fairview, Quezon
City.
You are occupying the above-described lot of our client illegally,
hence, this demand for you to peacefully vacate the same within ten
(10) days from receipt hereof. Should you fail or refuse to heed the just
and valid demand of our client, much to our regret, we shall be
constrained to institute appropriate action in court to recover its
possession from you.
Page | 44

We will appreciate very much your prompt and appropriate


action on the matter so that we shall all be spared from the
unnecessary rigors and expense appurtenant to court actions.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

April 6 2017

HON. MILAGROS D. DEQUINA


Records Officer II
Registry of Deeds, Quezon City

Madam:

In the spirit of public service, our warmest greetings!

Previously, you issued a certification dated September 17,


2014 certifying that “all documents, relative to TCT-
45792/45793 (11926) leading to the issuance to TCT-361704
at the Office of the Registry of Deeds prior to June 11, 1988
were all burned during the fire that razed the Quezon City
Hall Building on the said date.”
(Pls. see attached copy for your reference).

In view whereof, may we request for issuance of new


certification to the effect that the subject certificate of title “WAS Page | 45
NOT INCLUDED AMONG THOSE SAVED TITLES DURING THE
FIRE THAT RAZED THE QUEZON CITY HALL BUILDING LAST
JUNE 11, 1998, the documents leading to its issuance were
burned,” or any wording or statement of similar tenor and
import.

As ever, we express our heartfelt appreciation for your


prompt and positive action on our request.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
March 10, 2017

EMILIA DE GUZMAN/
JOSE PANGANIBAN/
JEFFREY ORDONEZ AND ALL PERSONS
DERIVING AND/OR
CLAIMING RIGHTS UNDER YOU
Army Road, Ph-5, Sitio Labahan
Brgy. Silangan, San Mateo, Rizal

Re: Demand to Vacate & To Pay Damages

Dear Mr.& Mrs. De Guzman/


Jose Panganiban/Jeffrey Ordonez:
This refers to your undertaking and commitment under the
“Kasunduan at Kapangakuan” dated November 7, 2016 to voluntarily
and VACATE and/or to peacefully SURRENDER on or before December
25, 2016 that parcel of land occupied by you in order to avoid litigation
and payment of damages.
Page | 46
It appears that contrary to your said commitment and despite
the fact that you have already received the agreed financial assistance
in the amount of P700,000.00 on November 7, 2016, up to this date,
you failed and refused and continue to fail and refuse to vacate the
land subject of the Kasunduan at Kapangakuan dated November 7,
2016 to the damage and prejudice of former RTC Judge Vivencio S.
Baclig.

In view whereof, we are constrained to give you this last and final
notice for you to vacate the subject property within five (5) days from
receipt hereof otherwise we will be constrained to enforce the provision
of the Kasunduan to the effect that you shall be forcibly evicted from
the subject land without writ or order from the court and you shall
likewise be required to pay the agreed damages in the amount of
P700,000.00

We trust that you will act accordingly so that we shall all be


spared from incurring unnecessary litigation expenses and of being
held liable for damages.

Yours truly,

DANNY F. VILLANUEVA

March 10, 2017

MR. LUDENILO S. ADOR


Sheriff IV, Branch 16, Regional Trial Court
Eight Judicial Region, Naval, Biliran

Re: SHERIFF’S SALE OF THAT LEVIED REALTY


COVERED BY ARP NO. 00280 relative to execution of judgment in
Rodco Consultancy & Maritime Corp. vs. Paulo R. Gutierez & Leila
B. Gutierez, docketed as Civil Case No. N-C21591

Dear Sheriff Ador:

In the name and spirit of efficient and expeditious


administration of justice, our warmest greetings!
This refers to the above request of our client for you to
proceed with the conduct of execution sale of that piece of realty
covered by ARP No. 00280 situated at Binalayan West, Maripipi,
Biliran Province.

As you have already levied the subject property, it behooves Page | 47


you to proceed in the conduct of the auction sale in accordance
with the provisions of Rule 39 of the Revised Rules of Court.

We trust that you will act promptly and accordingly in order


for our client to reap the fruits of its victory in court.

Thank you for giving this request your due attention and
action.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
November 19, 2016

BEN DE GUZMAN/EMILIA DE GUZMAN/


CONGRESSMAN JOSE PANGANIBAN/
JEFFREY ORDONEZ AND ALL PERSONS
DERIVING AND/OR
CLAIMING RIGHTS UNDER YOU
Army Road, Ph-5, Sitio Labahan
Brgy. Silangan, San Mateo, Rizal

Re: Demand to Vacate & To Pay Damages

Dear Mr.& Mrs. De Guzman/


Hon. Jose Panganiban/Jeffrey Ordonez:

This refers to the above matter referred to us by our clients, the


Heirs of Isagani Raneses, the Heirs of Savellano, Atty. Walter Young,
Mr. Alipoon, and Judge Vivencio S. Baclig for the taking of appropriate
action against you for the recovery of the lots being occupied by you
and your family as well as by people claiming rights and/or deriving
rights under you.

According to our clients, your stay and use of the subject lots
were by the mere tolerance of our clients. Our clients now need the
subject property for their own use, hence, we hereby demand that you
Page | 48
voluntarily vacate and peacefully turn over the same to our clients
within five (5) days from receipt hereof, otherwise, much to our regret,
we shall be constrained to institute the appropriate ejectment
proceedings to recover the possession of the land from you and from
all those claiming rights under you.

We trust that you will act accordingly so that we shall all be


spared from incurring unnecessary litigation expenses and of being
held liable for damages.

Thank you for giving this demand your due attention and action.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

November 2, 2016

Hon. JOSE T. PANGANIBAN


Anac-IP Party List
No. 6, Road 7, Pag-asa, Quezon City

Re: Request to Vacate Lot in Brgy. Silangan, San Mateo,


Rizal

Sir:

In the spirit of peace and brotherly love, our warmest greetings!


This refers to that parcel of land situated in Brgy. Silangan, San
Mateo, Rizal, a portion of which is occupied by your Cock Breeding
Farm pursuant to your contract of lease with the late Ben de Guzman
and family through Leopoldo Garde.

The entire parcel was acquired by a brother in the Iglesia Ni


Page | 49
Cristo who intends to put up a low-cost housing for our brethren in the
Church. Our brother-client will commence site development works in
the subject lot in the first week of December, 2016, hence, this very
respectful plea and request.

Sir, please vacate the lot on or before November 30, 2016 so that
earth-moving works can proceed without further delay.

We will appreciate very much your kind cooperation and usual


kind accommodation.

Yours truly,

DANNY F. VILLANUEVA

MR. JEFFREY ORDONEZ


C/O Ruben De Guzman Compound
AFP Rd., Brgy. Silangan
San Mateo, Rizal

Re: Request to Vacate Lot in Brgy. Silangan, San Mateo,


Rizal

Kind Sir:

In the spirit of peace and brotherly love, our warmest greetings!

This refers to that parcel of land situated in Brgy. Silangan, San


Mateo, Rizal, a portion of which is occupied by your Cock Breeding
Farm pursuant to your contract of lease with the late Ben de Guzman
and family.

The entire parcel was acquired by a brother in the Iglesia Ni


Cristo who intends to put up a low-cost housing for our brethren in the
Church. Our brother-client will commence site development works in
the subject lot in the first week of December, 2016, hence, this very
respectful plea and request.
Sir, please vacate the lot on or before November 30, 2016 so that
earth-moving works can proceed without further delay.

We will appreciate very much your kind cooperation and usual


kind accommodation.
Page | 50

Yours truly,

DANNY F. VILLANUEVA

Received:
___________________

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

18 February 2017

HON. CECILIO C. HERNANDEZ


Mayor, Municipality of Rodriguez, Rizal

Sir:

In the spirit of public service, our warmest greetings!

May we respectfully request for an audience with you to


present and discuss with you and the members of the
Sangguniang Bayan the Montalban Doronila Eco-tourism Project.
We will highly appreciate if your schedule can accommodate
us in the morning of February 22, 2017 at your Office.

As ever, we express our wholehearted supported to you and


your administration in making Rodriguez, Rizal, a model
community for sustainable and inclusive development that would Page | 51
bring prosperity to its constituents.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

February 1, 2017

ENGR. CARLO ANGELO M. ALVIZ


BIZ Partner Manager
Biz Partners Group
Marikina Business Center
Molave cor. Bayan-Bayanan Ave.
Concepcion Uno, Marikina City

Re: Demand for Discontinuance/Disconnection of Electricity


Supply at the Quarry Sites/Crushing Plant Belonging to
Pacific Concrete Products, Inc. (PCPI) and Vulcan Page | 52
Industrial & Mining Corporation, Brgy. San Rafael,
Rodriguez, Rizal

Sir:

This refers to the above demand/matter referred to us by our


client, the Doronila Estate, represented by Dr. Dennis C. Asensio of
Montevista Subdivision, No. 1 Narra St., Barangka Markina City, for
the taking of all appropriate actions to accomplish the above-stated
objective of causing you to cut, stop and discontinue the provision of
electricity or energy supply at the quarry sites belonging to PCPI and
Vulcan Industrial.

The property known as Doronila Estate is a vast tract of land


consisting of Lots 18, 19, and 20, situated at Brgy. San Rafael,
Rodriguez, Rizal, and the said lots are embraced by Transfer
Certificates of Title Nos. 219959 and 224238.

It may help you to know that the contract of operation covering


Lot 18 between PCPI and our client has expired as early as November
20, 2016 and the same has not been extended and/or renewed. Also,
the contract of Vulcan Industrial over Lot 19 with our client has
expired much earlier on February 12, 2015 and the same has also not
been extended and renewed.

Moreover, it may also help you to know that the quarry


operations of both companies in the area had already been ordered
stopped by the Mines and Geosciences Board (MGB) and the DENR,
hence, further quarry operations in the area are being done in grave
violation of law resulting to serious environmental damage.

Meanwhile, our client demands for the immediate stoppage


and/or discontinuance of the electric supply in the area as above-
stated to obviate and prevent further violations of laws and
commission of environmental offenses by both PCPI and Vulcan
Industrial & Mining Corporation. Meralco shall be informed in writing
by Asevidor or by Dr. Asensio through us when electrical supply shall
again be continued and/or reconnected for the rehabilitation works of
the area to be undertaken by Asevidor Land Management Corporation
in the very near future.

Your immediate action is highly enjoined to avoid criminal and


damages suits by our client against the perpetrators of the illegal acts
including against Meralco if the lawful and valid demand of our client
be not acted upon immediately.
Yours truly,
Page | 53

DANNY F. VILLANUEVA

Cc: Dr. Dennis C. Asensio


MonteVista Subd., No. 1 Narra St.,
Barangka, Marikina City

BACLIG & VILLANUEVA


Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
January 12, 2017

THE HONORABLE CIVIL REGISTRAR GENERAL


Philippine Statistics Authority
East Ave., Quezon City
Re: Request for Death Certificate;
Benigno E. Medina, Jr
Date of Death: Nov. 8, 2009
Page | 54

Sir/Madam:

In the spirit of public service, warm greetings!

Relative to Civil Case No. 10-67084 entitled Froilan G.


Clemente, Jr. vs. Sps. Benigno E. Medina, Jr. and Lyn Lien
Aressas Medina, pending before Branch 88 of the Regional Trial
Court of Quezon City, may we respectfully request for certified
electronic or true copy of the death certificate of Benigno E.
Medina, Jr. who died on November 8, 2009 as duly reported and
appearing in the records of death in your Office after payment of
the applicable fees.

For the above-stated purpose, Our Office has authorized


EDDIE MALAZZAB to file the requisite application and receive the
requested copy.

Your prompt action on the matter will be highly appreciated.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
December 8, 2016

GEN. JORGE E. CORPUZ (Ret.)


Chairman, Philippine Charity Sweepstakes Office (PCSO)
Sun Plaza Building, 1507 Shaw Blvd. cor.
Princeton St., Mandaluyong City 1552
Re: Request for Transfer of Lotto Terminal and
Return of PCSO Machine by Sarah M. Al-Rasheed

Sir:
Page | 55
This refers to the above matters referred to us by our client, Consolita
R. Totanes, of No. 2322 Guadalupe Mansion, Brgy. Cembo, Makati City.

Ms. Totanes is an accredited Lotto Agent of PCSO. She has a pending


application before PCSO NCR Department Manager, Josefina A. Sarsonas,
which up to now has not been acted upon, allegedly, for the reason that the
Lotto Machine installed in the old/former outlet has not been returned to
PCSO.

Ms. Sarah M. Al-Rasheed who is also a PCSO Lotto Agent refused and
continues to refuse to return to the PCSO the Lotto Machine installed at my
old lotto outlet currently operated by Ms. Al-Rasheed.

Sir, our client feels that Ms. Sarsonas of PCSO-NCR is not exerting
enough effort to recover from Ms. Al-Rasheed the Lotto Machine so much so
that the approval of her application for new outlet is being withheld. Our
client had already done her best and all that she can in order to compel Ms.
Al-Rasheed to return to PCSO the equipment but all her efforts proved futile
as Ms. Al-Rasheed had refused to cooperate with the PCSO NCR in the
return of the equipment and in the approval of the application for transfer of
site. An action for Replevin to recover the machine is not also feasible as the
equipment belongs to the PCSO, thus, it is PCSO that has personality to
institute action to recover the subject Lotto Machine.

In view whereof, we most respectfully request intervention by your


Good Office to expedite the approval of our client’s aforesaid application for
transfer of site and the recovery by PCSO of its lotto equipment from Ms.
Sarah Al-Rasheed.

We will highly appreciate your kind accommodation and prompt action


on our humble request.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

December 9, 2016

THE PRESIDENT/MANAGER
Dominus Construction and
Services Corporation
___________________________
___________________________

Page | 56
Re: Demand to Pay UCPB Check Nos. MLN
0007285514 and 0007285515 for
P187,072.92 and
P90,000.00

Sirs/Mesdames:

This refers to the above matter referred to us for immediate legal


action by our client, AMELITA P. BAUTISTA of Maygold Construction
Supply of Tanauan, Batangas.

The total amount represented by the two (2) checks is


P277,072.00 plus the applicable legal interest as the obligations under
the two (2) checks had become due and demandable on November 5
and 19, 2016 respectively.

In view whereof, we request you to pay the afore-stated amount


within five (5) days from receipt hereof. Should we not hear from you
within the said period, we shall be constrained to institute all
appropriate action in court in order to collect the subject indebtedness.

Your prompt payment will save you and our client from the
unnecessary expenses and hassle that come with court actions.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

December 8, 2016
ESTELA TOMANENG
LEAH TOMANENG
National Rd., Barangay Baclig
Cabugao, Ilocos Sur

Page | 57
Re: Demand to Pay

Mesdames:

This is to demand payment of the principal amount of Three


Hundred Thousand Pesos (P300,000.00) plus 5% interest per month
as agreed under the Promissory Note dated November 30, 2011
executed by the late Ernesto Tomaneng in favor of our client, Vivencio
S. Baclig. Copy of the said Promissory Note is attached for your ready
reference.

The total amount payable under the note as of this date is One
Million and Thirty Five Thousand Pesos (P1,035,000.00).

In view whereof, we request you to pay the afore-stated amount


within ten (10) days from receipt hereof. Should we not hear from you
within the said period, we shall be constrained to institute all
appropriate action in court in order to collect the subject indebtedness.

Your prompt payment will save you and our client from the
unnecessary expenses and hassle that come with court actions.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
February 1, 2017

THE HONORABLE ASSESSOR


Sta. Maria, Bulacan
Page | 58
Municipal Hall, Sta. Maria, Bulacan

Re: Request to Produce and Submit


Documents/Papers to the Court

Sir/Madam:

In the spirit of public service, warm greetings!

This refers to the above matter in connection with the


Motion for Issuance of Subpoena filed by our client, Marcelina
Limon, before Branch 7 of the Regional Trial Court of Malolos,
Bulacan in Civil Case No. 275-M-2016.

The Honorable Court directed the undersigned to write this


letter requesting you or your representative--

 To bring and submit to Branch 7, RTC, Malolos,


Bulacan, copy furnished the undersigned, the
following documents: The tax declaration covering
Transfer Certificate of Title (TCT) No. T-182786
(M) (cancelled title in the name of Flocerfina
Garcia); and the tax declaration pertaining to
TCT No. 040-2015024346 in the name of Sps.
Abelardo DR Santos, Jr. and Agnes Santos which
covers that parcel of land situated at Aba
Eatery, Km. 38, Pulong Buhangin, Sta. Maria,
Bulacan; Date of Absolute Sale dated July 7,
2015; and such other documents and papers
supporting the transfer and Registration of the
title to Sps. Abelardo Santos, Jr. and Agnes
Santos.

Your prompt action on the matter will be highly appreciated.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

15 November 2016
Page | 59

HON. ALDRIN CUNA


City Administrator, Quezon City
Quezon City Hall Complex

Sir:

In the spirit of public service, warm greetings!

Our brother in Christ, ERWIN M. ORMITA, presently a JO


employee assigned at the Department of Public Order and Safety
(DPOS) has served the City for more than nine (9) years already.

May I respectfully endorse and recommend Mr. Ormita to


any of the available plantilla positions suited to his qualifications
and experience.

Your usual kind accommodation and favorable action on


this recommendation will be highly appreciated.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.) Page | 60
Atty. Danny F. Villanueva, Ph.D.

November 2, 2016

Hon. JOSE T. PANGANIBAN


Anac-IP Party List
No. 6, Road 7, Pag-asa, Quezon City

Re: Request to Vacate Lot in Brgy. Silangan, San Mateo,


Rizal

Sir:

In the spirit of peace and brotherly love, our warmest greetings!

This refers to that parcel of land situated in Brgy. Silangan, San


Mateo, Rizal, a portion of which is occupied by your Cock Breeding
Farm pursuant to your contract of lease with the late Ben de Guzman
and family through Leopoldo Garde.

The entire parcel was acquired by a brother in the Iglesia Ni


Cristo who intends to put up a low-cost housing for our brethren in the
Church. Our brother-client will commence site development works in
the subject lot in the first week of December, 2016, hence, this very
respectful plea and request.

Sir, please vacate the lot on or before November 30, 2016 so that
earth-moving works can proceed without further delay.

We will appreciate very much your kind cooperation and usual


kind accommodation.

Yours truly,

DANNY F. VILLANUEVA
MR. JEFFREY ORDONEZ
C/O Ruben De Guzman Compound
AFP Rd., Brgy. Silangan
San Mateo, Rizal
Page | 61
Re: Request to Vacate Lot in Brgy. Silangan, San Mateo,
Rizal

Kind Sir:

In the spirit of peace and brotherly love, our warmest greetings!

This refers to that parcel of land situated in Brgy. Silangan, San


Mateo, Rizal, a portion of which is occupied by your Cock Breeding
Farm pursuant to your contract of lease with the late Ben de Guzman
and family.

The entire parcel was acquired by a brother in the Iglesia Ni


Cristo who intends to put up a low-cost housing for our brethren in the
Church. Our brother-client will commence site development works in
the subject lot in the first week of December, 2016, hence, this very
respectful plea and request.

Sir, please vacate the lot on or before November 30, 2016 so that
earth-moving works can proceed without further delay.

We will appreciate very much your kind cooperation and usual


kind accommodation.

Yours truly,

DANNY F. VILLANUEVA

Received:
___________________
Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman, Page | 62
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

November 2, 2016

MR. RODOLFO M. CAJULIS/


JOSE MARIA P. YABUT
Maribrid Farm, C/O Ruben de Guzman
AFP Rd., Brgy. Silangan
San Mateo, Rizal

Re: Request to Vacate Lot in Brgy. Silangan, San Mateo,


Rizal

Sirs:

In the spirit of peace and brotherly love, our warmest greetings!

This refers to that parcel of land situated in Brgy. Silangan, San


Mateo, Rizal, a portion of which is occupied by your Cock Breeding
Farm pursuant to your contract of lease with the late Ben de Guzman
and family.

The entire parcel was acquired by a brother in the Iglesia Ni


Cristo who intends to put up a low-cost housing for our brethren in
the Church. Our brother-client will commence fencing works in the
subject lot as soon as possible, hence, this very respectful plea and
request to vacate.

Sirs, kindly make the lot vacant and available on or before


November 30, 2016 so that construction works can proceed without
delay.

We will appreciate very much your kind cooperation and usual


kind accommodation.

Yours truly,
DANNY F. VILLANUEVA
Received:
___________________

The Honorable Registrar of Deeds


Page | 63
Registry of Deeds, Marikina City
J.P. Rizal Ave., Marikina City

Sir/Madam:

In the spirit of public service, our warmest greetings!

May we respectfully request for certified electronic copy of


Transfer Certificate of Title No. 150077 in the name of Amparo S.
Tamisin which covers a parcel of land situated in Barangay Silangan,
San Mateo, Rizal.

Kindly entrust the copy of the requested document to Michael S.


Pelayo.

We sincerely appreciate your usual prompt and favorable action.

Yours truly,

DANNY F. VILLANUEVA

Hon. _____________ PANGANIBAN


Congressman, House of Representatives
Batasan Hills, Quezon City/
6th St., Brgy. Pag-asa, Quezon City

Page | 64
Re: Request to Vacate Lot in Brgy. Silangan, San Mateo,
Rizal

Sir:

In the spirit of public service, our warmest greetings!

This refers to that parcel of land situated in Brgy. Silangan, San


Mateo, Rizal, presently occupied by you pursuant to a contract of lease
with the late Ben de Guzman.

The entire parcel was acquired by a brother in the Church of


Christ who intends to put up a low-cost housing for our brethren in
the Church. Our brother-client will commence fencing of the subject
lot as soon as possible, hence, this very respectful plea and request to
vacate.

Sir, kindly make the lot vacant and available on or before


November 30, 2016 so that construction works can proceed
unhampered.

We will appreciate very much your kind cooperation and usual


kind accommodation.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

Oct. 28, 2016

The Honorable Assessor


Page | 65
Municipal Assessor’s Office
San Mateo, Rizal

Sir/Madam:

In the spirit of public service, our warmest greetings!

May we respectfully request for certified electronic copy of the tax


declaration covering Transfer Certificate of Title (TCT) No. 459169 in
the name of Isagani P. Raneses married to Mercedes Valdes, pertaining
to a parcel of land situated in Barangay Silangan, San Mateo, Rizal.

Kindly entrust the copy of the requested document to Michael S.


Pelayo.

We sincerely appreciate your usual prompt and favorable action.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033 Page | 66
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
Oct. 26, 2016

SARAH M. AL-RASHEED
No. 9 Meliton Espiritu Ave., Paranaque City

Re: Demand to surrender/turn-over Lotto Machines

Dear Madame:

Warmest greetings!
This refers to the above demand of our client, CONSOLITA
REPOSO TOTANES, of No. 2322 Guadalupe Mansion, J.P. Rizal Ext.,
Barangay Cembo, Makati City.

According to Mrs. Totanes, the subject Lotto Machines belong to


the PCSO and upon closure or cessation of the lotto outlet must be
duly returned to the PCSO by the authorized agent.

We understand that the operation of the lotto outlet or that


business known as TACS Lotto Sales Agent with business
establishment at Mo. 585 corner Ma. Socorro St., Finasia Homes, San
Antonio Valley 1, Paranaque City which had been assigned to you by
our client under the Deed of Assignment/Transfer of Rights dated
November 21, 2011 but said assignment refers only to the right to
continue the operation of said lotto outlet and the assignee is bound to
return the Lotto Machines upon closure of the outlet.

In view whereof, we hereby give this final demand to turn over or


surrender the Lotto Machines used at the Tacs Lotto Outlet assigned
to you by our client within five (5) days from receipt hereof, otherwise,
much to our regret, if you will continue on refusing to surrender the
machines, we shall be constrained to institute all appropriate actions
in court to secure the possession of the subject machines and to hold
you liable for all the damages sustained and expenses incurred by our
client.

Please be guided accordingly so that unnecessary litigation would


be avoided.

Yours truly,
DANNY F. VILLANUEVA

BACLIG & VILLANUEVA Page | 67


Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

17 October 2016

The Honorable Barangay Chairman


Barangay Tanauan, Dingalan, Aurora

Re: Authority to Evict, Etc.

Sir/Madam:

This is to authorize CIRIACO M. CALBONERO to evict Rolando


Condez and family from my house and lot situated in your Barangay.

Mr. Calbonero is my caretaker administrator in respect to all my


lots including the one presently occupied by the said Mr. Condez.

In view whereof, kindly entertain and act on the complaint for


ejectment filed by Mr. Calbonera against Mr. Condez and family and if
there is a way, please help Mr. Calbonero collect the accumulated
unpaid P200 monthly rentals from Mr. Condez.

Thank you very much.

Yours truly,

DANNY F. VILLANUEVA
Page | 68
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

Sept. 27, 2016

The Honorable Registrar of Deeds


Registry of Deeds, Quezon City
LRA Compound, Brgy. Pinyahan
Quezon City

Sir:

In the spirit of public service, our warmest greetings!

May we respectfully request for true electronic copies of the


following documents which support the registration of Entry No.
2015035472, Affidavit of Loss, annotated upon Transfer Certificate of
Title No. (262266) PR-31468, copy of which is attached for your
perusal and reference:

1. Affidavit of Loss executed by Joey Belza Delloro;


2. Deed of Sale dated November 10, 2012; and
3. Secretary’s Certificate dated January 12, 2015.

We sincerely appreciate your usual prompt and favorable


action.

Yours truly,
VIVENCIO S. BACLIG

Page | 69

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

Sept. 26, 2016

MR. BADRELIN ELZAKE EL HABBIB


No. 7, Purok 6, Pinsao Pilot Project, Baguio City

No. 2328 Cityland, Pasong Tamo Condo


2210 Chino Roses Ave., Makati City

Re: Demand to Pay P210,000, Interest and Damages

Sir:

This refers to the demand of our client, Carnavan Car Rental


Services, Inc., for the payment of car rental arrears in the above-
stated amount.

We strongly advise you to settle your obligations to our


client within five (5) days from receipt hereof otherwise much to
our regret, we shall be constrained to sue you in court in order to
collect the amount due to our client as well as make you liable for
interest, other expenses and damages pursuant to your car rental
agreement with our client.

Thank you very much for your due attention and prompt
action on the matter.
Page | 70

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

Sept. 26, 2016

RUNE BERENTSEN
_____________________________

_____________________________

Re: Demand to Pay P411,100, Interest and Damages

Sir:

This refers to the demand by our client, Carnavan Car


Rental Services, Inc., for the payment of car rental arrears in the
above-stated amount.

We strongly advise you to settle your obligations to our


client within five (5) days from receipt hereof otherwise much to
our regret, we shall be constrained to sue you in court in order to
collect the amount due to our client as well as make you liable for
interest, other expenses and damages pursuant to the car rental
agreement.

Thank you very much for your due attention and prompt
action on the matter.
Page | 71

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

Sept. 26, 2016

RUNE BERENTSEN
_____________________________

_____________________________

Re: Demand to Pay P411,100, Interest and Damages

Sir:

This refers to the demand by our client, Carnavan Car


Rental Services, Inc., for the payment of car rental arrears in the
above-stated amount.

We strongly advise you to settle your obligations to our


client within five (5) days from receipt hereof otherwise much to
our regret, we shall be constrained to sue you in court in order to
collect the amount due to our client as well as make you liable for
interest, other expenses and damages pursuant to the car rental
agreement.

Thank you very much for your due attention and prompt
action on the matter.
Page | 72

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
Sept. 23, 2016

REX ORA
Account Executive, BFS and BHFI
_____________________________
_____________________________

Re: Demand for Reimbursement & for Damages

Dear Mr. Ora:

This refers to the above-stated demand by our client, Froilan


G. Clemente, Jr., for reimbursement of all the expenses he
incurred and the damages he sustained by reason of your
fraudulent and lawless action in inducing him to secure the
conformity of Mr. Omillo to the sale/bail out of that property
described as Lot 2, Block 5, Spring III, Camarin, Caloocan
covered by TCT No. 248937 but after he worked for the execution
of Deed of Sale with Assumption of Mortgage for a consideration
of P20,000.00 (copy of the said document is attached for your
reference and perusal), you caused the sale of the said property to
Josefina Tan without first getting the conformity of our client.

Your said action is not in keeping with good faith and good Page | 73
human relationship. The law considers it as actionable wrong—a
tort which caused damage to our client.

We strongly advise you to reimburse and compensate Mr.


Clemente in an amount of at least P100,000.00 within five (5)
days from receipt hereof otherwise much to our regret, we shall
be constrained to sue you in court in order to recover the subject
property from BFS and from Josefina Tan as well as make you
liable for all the expenses incurred and the damages sustained by
our said client.

Thank you very much for your due attention and prompt
action on the matter.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

Sept. 23, 2016

JOSEFINA TAN
Lot 2, Blk. 5, Palmera Spring III
Camarin, Caloocan City

Re: Demand To Pay P50,000.00

Dear Ms. Tan:

This refers to the above-stated demand by our client, Froilan


G. Clemente, Jr., for reimbursement of all the expenses he
incurred and the damages he sustained by reason of your
fraudulent and lawless action in directly dealing with Balikatan
Financial Services, Inc. (BFS) whereby you induced BFS to sell to
you directly the property you are now occupying which was
previously acquired by our client from Bernardo F. Omillo for
P20,000.00 as evidenced by Deed of Sale with Assumption of
Mortgage copy of which is attached for your reference and Page | 74
perusal.

We strongly advise you to settle the just demand of Mr.


Clemente within five (5) days from receipt hereof otherwise much
to our regret, we shall be constrained to sue you in court in order
to recover the subject property from you as well as the expenses
incurred and the damages sustained by our said client.

Thank you very much for your due attention and prompt
action on the matter.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

Sept. 23, 2016

IMELDA BARDON
Managing Partner
V8 Racer Motor Co., Ltd.
81-A, Building II
_______________________________
_______________________________
Page | 75

Re: Notice that the Property subject of the


Contract of Lease is FOR SALE

Madam:

Warm greetings!

Please take notice that the property (covered by TCT Nos. N-


293918 and N-269339), subject of your contract of lease with
Sps. Alejandro is now being offered for sale to the general public.

If you are interested to exercise your option as Lessee,


please let us know within five (5) days from receipt hereof.

Your failure to notify us or to make the necessary


correspondence within the above-stated period shall be taken and
considered as lack of interest to buy or to exercise option and/or
waiver of any right that you may have under the law and under
the contract of lease.

Please be guided accordingly.

Yours truly,

DANNY F. VILLANUEVA
Counsel for Sps. Jesus J. Alejandro
and Remedios M. Alejandro

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

Sept. 18, 2016

Page | 76
ATTY. OSCAR CARLO F. CAJUCOM
LEOGARDO & MAGTANONG
6th Floor Filinvest Building, No. 79 EDSA, Highway Hills,
1550 Mandaluyong City, Metro Manila

Companero:

Our warmest greetings!

This is a follow-up to our client’s demand for full payment of


their billing to Filinvest Land, Inc. (FLI) and the Linear
Condominium Corporation (LCC).

We maintain our position that it is wrong for FLI to deduct


“the amount of P441,964.30” from BCSA’s “final billing of
the captioned contract”.

In view of the above, we are making this final demand for


voluntary settlement of FLI’s obligation to BCSA, otherwise, much
to our regret, we shall be constrained to go to court to collect the
amount due to our said client.

Thank you very much for your due attention and prompt
action on the matter.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D. Page | 77

Sept. 18, 2016

ATTY. OSCAR CARLO F. CAJUCOM


LEOGARDO & MAGTANONG
6th Floor Filinvest Building, No. 79 EDSA, Highway Hills,
1550 Mandaluyong City, Metro Manila

Companero:

Our warmest greetings!

This is a follow-up to our client’s demand for full payment of


their billing to Filinvest Land, Inc. (FLI) and the Linear
Condominium Corporation (LCC).

We maintain our position that it is wrong for FLI to deduct


“the amount of P441,964.30” from BCSA’s “final billing of
the captioned contract”.

In view of the above, we are making this final demand for


voluntary settlement of FLI’s obligation to BCSA, otherwise, much
to our regret, we shall be constrained to go to court to collect the
amount due to our said client.

Thank you very much for your due attention and prompt
action on the matter.

Yours truly,

DANNY F. VILLANUEVA
Page | 78

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 3645814; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio S. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
September 18, 2016

The Honorable Clerk of Court


Branch 77, Regional Trial Court
Quezon City
Hall of Justice, Quezon City

Sir:

Warmest regards!

May we respectfully request for certified true copies of


the following documents issued and/or part of the record of LRC
Case No. Q-9068 (97):

(1) Writ of Execution dated February 22, 2008;


(2) Decision dated December 29, 2000;
(3) Court of Appeals Decision dated July 18, 2003; and
(4) Certificate of Finality

We will highly appreciate your usual due attention and


prompt action.
Yours truly,
Page | 79

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 3645814; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio S. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
September 18, 2016

The Honorable Registrar of Deeds


Registry of Deeds, Quezon City
LRA Compound, NIA Rd.
Brgy. Pinyahan, Quezon City

Re: Request for Certified Electronic Copies of (1) Writ of


Execution (PE-5137) issued by Branch 77, Quezon City dated
February 22, 2008; (2) Decision (PE-5139) dated December 29, 2000 in
LRC Case No. Q-9068 (97); and Court of Appeals Decision dated July
18, 2003 all annotated upon TCT No. RT-229507 (242456), copy is
attached

Sir:

In the name of public service, our warmest regards!

We will highly appreciate your usual prompt action on our


above-stated request.
Yours truly,

Page | 80

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 3645814; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio S. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
September 18, 2016

RONALD EMBUDO/
WALDO EMBUDO &
ALL PERSONS DERIVING AND/OR
CLAIMING RIGHTS UNDER YOU
Relocation Site, Army Rd. Ph-5
Brgy. Silangan, San Mateo, Rizal

Re: Demand to Vacate & To Pay Damages


TCT No. 280087, RD of Marikina City

Dear Sirs/Mesadames:

This refers to the above matter referred to us by our clients, the


Heirs of Isagani Raneses, for the taking of appropriate action against
you for the recovery of the subject lot which you unlawfully occupy to
the prejudice of our said clients.
According to our clients, your stay and use of the subject lot was
by the mere tolerance of the Raneses family. Our clients now need the
subject property for their own use, hence, we hereby demand that you
voluntarily vacate and peacefully turn over the same to our clients
within ten (10) days from receipt hereof, otherwise, much to our regret,
we shall be constrained to institute the appropriate eviction/accion
Page | 81
publiciana proceedings to recover the possession of the land from you
and from all those claiming rights under you.

We trust that you will act accordingly so that we shall all be


spared from incurring unnecessary litigation expenses and of being
held liable for damages.

Thank you for giving this demand your due attention and action.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 3645814; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio S. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D. 07 September 2016

RONNIE L. APEROCHO
First Vice President/Head of Networks
MERALCO, Lopez Bldg, Ortigas Avenue
Brgy. Ugong, Pasig City

Re: Demand to Pay for the 182.25 Square Meters portion of TCT Nos. 039-
2015009988; 039-2015009985; 039-2015009986; and 039-2015009987-all subject
of the Deed of Absolute Sale between Meralco and Mr. Leoncio Barcelon and Sps.
Santos

Sir:

Our warmest greetings!

This refers to the above-stated matter referred to us by our


clients, Mr. Leoncio Barcelon and Sps. Roning and Florentina Santos
of Sto. Cristo, Pulilan, Bulacan, for the taking of appropriate legal
actions to collect the payment for the unpaid portion of 182.25 square
meters.

Under the subject Deed of Absolute Sale, Meralco bought from


our clients four (4) parcels of land with an aggregate area of 4,047
square meters but Meralco paid for 3,864.75 square meters only based
Page | 82
on its misrepresentation that only 3,864.25 square meters are actually
available as the 182.25 square meters were taken, devoted to and used
in the rip-rapping of the subject lots. Our survey of the subject lots
shows that the entire 4,047 square meters are available as the 182.25
square meters extend outside the existing perimeter fence which is
partly used as road right of way of the residents in the vicinity.

Per the sale of the subject lots, Meralco bought the subject lots at
P7,300 per square meter, thus, Meralco has a deficiency payment in
the amount of P1,330,425.00. In view whereof, demand is hereby made
for Meralco to pay to our clients P1,330,425.00 corresponding to the
unpaid 182.25 square meters as above-stated, within five (5) days from
receipt hereof.

We will appreciate very much if you could arrange prompt


payment of the said amount to our client.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
August 31, 2016

EDNA BATULAY &


ALL PERSONS DERIVING AND/OR
CLAIMING RIGHTS UNDER YOU
C/O Palmera Water Well
Army Road, Ph-5, Sitio Labahan
Brgy. Silangan, San Mateo, Rizal

Re: Demand to Vacate & To Pay Damages


TCT No. 354898, RD of Marikina City

Dear Ms. Batulay:


This refers to the above matter referred to us by our clients, the
Heirs of Isagani Raneses, for the taking of appropriate action against
you for the recovery of the subject lot covered by TCT No. 3459898.

According to our clients, your stay and use of the subject lot was
Page | 83
by the mere tolerance of the Raneses family. Our clients now need the
subject property for their own use, hence, we hereby demand that you
voluntarily vacate and peacefully turn over the same to our clients
within five (5) days from receipt hereof, otherwise, much to our regret,
we shall be constrained to institute the appropriate ejectment
proceedings to recover the possession of the land from you and from
all those claiming rights under you.

We trust that you will act accordingly so that we shall all be


spared from incurring unnecessary litigation expenses and of being
held liable for damages.

Thank you for giving this demand your due attention and action.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

03 September 2016

The Director
Bureau of Lands Land Management Bureau

Re: Carpeta of Lot 26, Blk. 242 Pld-13-002579


Under IGPSA- No. 007607-12015

Sir/Madam:
Our warmest greetings!

This is to request transmittal of all the pertinent records of the


above-stated lot in the name of Katherine S. Natividad to the Bureau of
Lands in Escolta, Manila considering that it is covered and governed
Page | 84
by a Presidential Proclamation.

We will highly appreciate your usual kind accommodation and


prompt action.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

03 September 2016

HON. ROEL O. PACAYRA


Barangay Chairman
Barangay Lower Bicutan
No. 01 C-6 Road, P5 Lower Bicutan, Taguig City

Re: Request for Issuance of Certification of


Residency/Occupancy of Lot 22, Pls-272 and 277
Mr. Chairman:

Our warmest greetings!

May we request your Good Office to issue to our client, Katherine


Natividad, a certification to the effect that she is a resident and/or the Page | 85
one in possession and occupancy of Lot 22, Pls-272 and 277 based on
the records pertaining to her payment of real property taxes and other
documents duly presented in your office relative to our said client’s
application for survey of the subject lot.

We were made to understand that the said application for


certification had been pending in your Office for more than a year
already. It is our understanding of the law that it is your ministerial
duty as Barangay Chairman to issue the requested certification within
a period not longer than fifteen (15) days.

We hope we have made ourselves clear on the matter and our


request will be acted upon expeditiously.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

31 August 2016

The Honorable General Manager


Laguna Lake Development Authority
Quezon City

Re: Payment of Fine imposed to Azzions Recycling


Solutions Inc. under the Order dated 10 August 2016 under Protest
Sir/Madam:

Our warmest greetings!


Page | 86
In our honest bid to fully cooperate with this Office in all its
avowed laudatory objectives and in order to obviate further injuries to
our client, Azzions Recycling Solutions, Inc., our said client is hereby
paying the fine imposed by your Good Office as above-stated without
prejudice to its right to seek appropriate legal remedies as we remain
firm in our stand that the Order dated 10 August 2016 lacked both
legal and factual bases.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D. 31 August 2016

MR. ROLANDO P. ATIENZA, JR.,


AVP, Bonds Department
Country Bankers Insurance Corporation
Country Bankers Centre
648 T.M. Kalaw Ave., Ermita, Manila

Re: Reiterative Request for Release of the Owner’s Copy of TCT No.
262292, and for Issuance of Release and Cancellation of REM
Sir:

Our warmest greetings!

Per your request, we are transmitting the pertinent records of


Civil Case No. 93-692 showing that the said case had already been Page | 87
terminated and that the judgment thereof does not and will not expose
CBIC to any liability under Injunction Bond No. JCL (8) 02280.

As regards the “unpaid period for the period from 1995 up to


present” in the amount of P74,481.32 being assessed by your
company, attached please find a crossed check for the said amount
which is being made by way of final settlement of whatever obligations
our client may have under the subject bond to obviate unnecessary
dispute and litigation expenses.

Please advise us ASAP as to when we can pick up the requested


documents. Please entrust the documents to MR. MICHAEL S.
PELAYO and/or MA. MIAH DELLORO who for the said purpose are
hereby authorized to sign any and all necessary documents and/or
receipts for your documentation.

We appreciate your prompt action.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
August 31, 2016

EDNA BATULAY &


ALL PERSONS DERIVING AND/OR
CLAIMING RIGHTS UNDER YOU
Army Road, Ph-5, Sitio Labahan
Brgy. Silangan, San Mateo, Rizal
Re: Demand to Vacate & To Pay Damages
TCT No. 354898, RD of Marikina City

Dear Ms. Batulay:

This refers to the above matter referred to us by our clients, the Page | 88
Heirs of Isagani Raneses, for the taking of appropriate action against
you for the recovery of the subject lot covered by TCT No. 3459898.

According to our clients, your stay and use of the subject lot was
by the mere tolerance of the Raneses family. Our clients now need the
subject property for their own use, hence, we hereby demand that you
voluntarily vacate and peacefully turn over the same to our clients
within five (5) days from receipt hereof, otherwise, much to our regret,
we shall be constrained to institute the appropriate ejectment
proceedings to recover the possession of the land from you and from
all those claiming rights under you.

We trust that you will act accordingly so that we shall all be


spared from incurring unnecessary litigation expenses and of being
held liable for damages.

Thank you for giving this demand your due attention and action.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D. 29 August 2016
MR. ANTONIO PE
President, City Square Realty Development Corp.
No. 110, Labo St., La Loma, Quezon City

Re: Notice/Advise of Take-Over of Possession


Page | 89
Dear Sir:

Our warmest greetings!

This refers to the above matter regarding the decision of El-Vi Realty &
Development Corporation to exercise its right under paragraph 19 of the
Lease Agreement dated 23 September 2011 which provides as follows:

“19. TAKE-OVER OF POSSESSION.—In case the Lessee fails to comply with


any of the terms hereof, such failure thereby authorizes the Lessor to take possession
of the property WITHOUT NECESSITY OF A COURT ORDER/JUDGMENT AND MAY
USE SUCH REASONABLE FORCE TO EFFECT SUCH RIGHT AND AUTHORITY
WITHOUT INCURRING ANY CIVIL OR CRIMINAL LIABILITY. For this purpose, the
Lessee hereby name, appoint and constitute the Lessor as its attorney-in-fact to
recover the physical possession of the building or any portion thereof. In such event,
the Lessee shall be duly advised in writing of such non-compliance by way of
reminder before the Lessor shall take over.”

The taking of the above action is justified because you failed to comply
with the provisions of the Lease Agreement pertaining to payment of monthly
rental as beginning the first year up to the last year of the period of the
lease, you only paid a monthly rental of P150,000.00 which rental amount
applies and is good only for the first year and not for the entire lease period.

Moreover, it appears that you do not intend to honor by vacating


peacefully the subject premises upon the expiration of the Lease Agreement,
thus, we are advising you that our client will resort to the use of reasonable
force in taking over the possession of the same based on the above-quoted
provisions of the Lease Agreement should you fail and/or refuse to
voluntarily leave the building on or before September 30, 2016.

Please be guided accordingly.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D. 24 August 2016
ATTY. OSCAR CARLO F. CAJUCOM
LEOGARDO & MAGTANONG
6th Floor Filinvest Building, No. 79 EDSA, Highway Hills,
1550 Mandaluyong City, Metro Manila

Re: Your Letter dated 5, 2016;


Page | 90
The Linear-Security Service Contract

Companero:

Our warmest greetings!

This refers to the above matter regarding the decision of Filinvest Land,
Inc. (FLI) and the Linear Condominium Corporation (LCC) to deduct “the
amount of P441,964.30” from BCSA’s “final billing of the captioned
contract”.

The said action of FLI and LCC is untenable for utter lack of basis both in
fact and in law, thus, we hereby demand full payment of the amount due our
client per the subject billing duly sent to your clients.

We maintain our stand that FLI and LCC should and could not hold BCSA
liable for the alleged loss of circuit breakers in the LCC on the assumption
that indeed the said CBs had been duly installed at the said project. Kindly
refer to the Investigation Report on Alleged Missing Circuit Breakers dated
July 7, 2015, copy of which was duly furnished to both FLI and LCC.

Offsetting does not properly apply in this case for the reason that your
clients’ obligation to our client is already due and liquidated while your
alleged claim against our client over the alleged loss of CBs has yet to be
proven. Per the information conveyed to us by our client, your clients have
yet to file the necessary and required criminal action for robbery or theft
against the culprits, thus, the obligation is not yet due, demandable and
liquidated.

In view of the above, consider this as our final demand to pay the final
billing of our client, otherwise much to our regret, we shall be constrained to
take and initiate appropriate action to collect what is due to our client.

Thank you very much for your due attention and prompt action on the
matter.

Yours truly,

DANNY F. VILLANUEVA

22 August 2016

ENGR. ISAGANI R. VERSOZA, JR.


City Building Official
Department of Building Official
Quezon City Local Government

Re: Fairhope Academy’s Application for Certificate of Occupancy


Page | 91
Sir:

Our warmest greetings!

This refers to the above-stated application for Certificate of


Occupancy pending before your good Office.

According to our said client, she is amenable that the nature of


the certificate of occupancy to be issued to Fairhope Academy, Inc. is
revocable in nature and subject to compliance of the following
conditions:

1. Fairhope will apply for Demolition Permit; and


2. Fairhope undertakes and commits to cause the demolition
of the concrete fence/wall encroaching around 1.5meters of the public
sidewalk.

Thank you very much for your usual kind accommodation and
prompt action on our request.

Yours truly,

DANNY F. VILLANUEVA
Counsel for Fairhope Academy, Inc.

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D. Page | 92
22 August 2016

ATTY. WILFREDO B. SARAOS


Legal Services, DENR Central Office
Visayas Ave., Quezon City

Re: Status of Case No. 8385; Mineral Production Application


denominated as MPSA Mining Located at Barrio Awang, Tagsulid
Opol, Misamis Oriental, Pacheco & Sons, Inc., Applicant

Companero:

Our warmest greetings!

This refers to the above matter referred to us by our client,


Pacheco & Sons, Inc. through its attorneys-in-fact, Michael Pelayo and
Edna M. Ponsica.

Before we will formalize our representation for the said client in


the subject case, we wish to secure pertinent orders and/or to be
acquainted with the actions so far taken by your good office on the
subject application.

Kindly allow Mr. Pelayo and Ms. Ponsica secure pertinent


documents and/or copies of any order or resolution issued by your
good Office.

Thank you very much for your usual kind accommodation and
prompt action on our request.

Yours truly,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA Page | 93

Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

AUTHORIZATION LETTER

This is to authorize ANALIZA O. CLINGENPEEL of No. 070


Rose St., Payatas A, Quezon City, to file, follow up, receive and get
any and all necessary papers in connection with the application
for Certificate of Authority to Register relative to the transfer of
that property described as Lot 10, Block 7, Sunnyside Subd.,
Batasan Hills, Q.C., registered in the name of Mover Enterprises,
Inc. in favor of Sps. Manaog, including the power to pay the
applicable taxes and receive the Certificate of Authority to
Register and other papers to be issued by the BIR.

VIVENCIO S. BACLIG
Page | 94

ANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
12 August 2016
THE HONORABLE MAYOR
Municipality of San Ildefonso, Bulacan
Municipal Hall, San Ildefonso, Bulacan

Attn: Ms. Evelyn G. Agudo


Municipal Treasurer

Re: Payment for Rental of Equipment

Dear Mayor Galvez-Tan:

In the spirit of “change” in public service, our warmest greetings!

This refers to the above demand of our client, Radthien Builders


Company, for the payment of equipment rentals, to wit:

Obligation Request No. 162592 –P22,031.25


Obligation Request No. 162593—P52,593.75
Obligation Request No. 162591—P24,308.03

The corresponding vouchers had long been signed by the former


Municipal Mayor and by the Municipal Accountant. Also, the Veterans
Bank checks corresponding to the payment of the above-stated
amounts pursuant to the Disbursement Vouchers had likewise been
prepared already by the Municipal Accountant but Ms. Agudo chose
not to issue despite availability of the same as early as June 16, 2016
for no known reason and cause.
In view whereof, final demand is hereby made for the
Municipality to pay to Radthien the subject equipment rentals within
five (5) days from receipt hereof, otherwise, much to our regret, we
shall be constrained to initiate appropriate legal actions including
bringing the matter to the Office of the Ombudsman due to the
Page | 95
unjustified delay and neglect on the matter which injures the
proprietary right of our client (Sec. 3, RA 3019).

Thank you for your attention and due action on our lawful
demand.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

12 August 2016

THE REGISTRAR
Land Transportation Office
La Loma Dist. Office
No. 3, Biak-na-Bato St., Brgy. Sta. Mesa Heights
Quezon City

Re: Request to Register/Annotate Chattel


Mortgage upon CR No. 13611231-4

Sir/Madam:

Kindly make/enter the appropriate annotation of the Chattel


Mortgage in favor of our client, Express Cash, Inc., on the Certificate of
Registration No. 13611231-4 in the name of Marte Hierco as the said
mortgagor had failed and refused and continue to fail and refuse to
pay his obligations to our client under the Promissory Note secured by
the said Chattel Mortgage constituted on the subject motor vehicle
under the above-stated certificate of registration.

Thank you for your usual kind assistance and prompt action on
Page | 96
our request.

Yours sincerely,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
August 12, 2016

LILIA L. VILLAS &


MA. LOURDES L. VILLAS
No. 12-D Agoncillo St., Brgy. Sta. Lucia
Novaliches, Quezon City

Re: Demand to Execute Deed of Absolute Sale

Mesdames:

This refers to that lot described as Lot 16, Blk. 2, San Bartolome,
Gulod, Sta. Lucia, Quezon City covered by Transfer Certificate of Title
No. 004-2016004249 of the Registry of Deeds of Quezon City which
you sold to your cousin, Evelina Matorre and for the second time, to
the undersigned.
You failed to honor you commitment to surrender the owner’s
copy of the subject title despite due demand. Moreover, under the law,
you have an obligation to execute the necessary deed of conveyance in
order for the undersigned to register the sale and transfer the title to
the subject property in his name.
Page | 97

In view whereof, the undersigned is giving you five (5) days from
receipt hereof within which to execute the necessary deed of sale in
registrable form and surrender all the pertinent documents to enable
the undersigned to register the title in his name as above-stated,
otherwise, much to our regret, we shall be constrained to institute all
civil actions against you to compel performance of your contractual
and legal obligations.

Be guided accordingly.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

12 August 2016

THE REGISTRAR
Land Transportation Office
La Loma Dist. Office
No. 3, Biak-na-Bato St., Brgy. Sta. Mesa Heights
Quezon City

Re: Chattel Mortgage/Encumbrance upon CR No.


13611231-4
Sir/Madam:

Kindly release the encumbrance inscribed by our client, Express


Cash, Inc. on the Certificate of Registration No. 13611231-4 in the
name of Marte Hierco as the said mortgagor had already fully paid and
settled is obligations to our client under the afore-stated chattel Page | 98
mortgage. Thus, we do not object to any transaction involving the
subject motor vehicle as the same had been released already from the
obligation it had secured.

Yours sincerely,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

August 12, 2016

THE HONORABLE BRANCH CLERK OF COURT


Branch 136, Regional Trial Court
Makati City

Sir/Madam:
Page | 99

This is to request copies of the following documents, re: Civil


Case No. 93-692:

Decision rendered in this case;


Certificate of Finality;
Pertinent orders pertaining to the termination of the
case

Kindly entrust the documents to our staff, MICHAEL S.


PELAYO.

Thank you for your usual kind accommodation and prompt


action on this request.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
August 12, 2016

ROSANA RUTH SAN JOSE FEDERICO


C/O LIZA BABAISON
Antipolo City

Dear Ms. Federico:


Page | 100

This refers to your Promissory Note dated April 13, 2016


whereunder you have committed to pay P160,000.00 in twelve monthly
installments of P13,350.00 starting May 31, 2016 and every month
thereafter until it is fully paid on April 30, 2017.

You failed to pay the amortizations for the months of May, June,
and July, 2016.

In view whereof, we hereby demand immediate payment of your


indebtedness, otherwise, much to our regret, we shall be constrained
to institute appropriate actions against you in order for us to recover
the said amount plus interest and costs of suit.

Thank you for giving this demand your due attention and action.

Yours truly,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
17 June 2016

THE HONORABLE CITY ASSESSOR


Quezon City Government
City Hall Complex
Page | 101

Attn: ATTY. GLYRIS LYN R. CABANSAG


OIC, Legal Division

Re: Request for Issuance of Addendum and/or Correction of


the Certificate of Sale, Warrant of Levy and Notice of Levy

Sir/Madam:

Warmest regards!

This pertains to the above-stated request of our client, Froilan G.


Clemente, Jr., of Quezon City, to reflect by issuing an addendum
and/or by making the necessary correction in the Certificate of Sale,
Warrant of Levy and Notice of Levy the fact that the property sold in
auction described as PSD-34147, Lot 2, Block 16, in Batasan Hills,
Quezon City covered by Tax Declaration ARP No. E-139-17090 00555-
2016-06-00041-9164 registered in the name of Dona Juana Subd., IS
COVERED BY TCT NO. 287579 as appearing in the corrected Tax
Declaration of Real Property copy of which is attached as Annex “A”
hereof.

The old Certificate of Sale, Warrant of Levy and Notice of Levy do


not reflect the above-stated fact, hence, the need for an addendum or
correction as above-requested.

Your prompt action on this humble request will be duly


appreciated.

Yours sincerely,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

30 June 2016
ATTY. FEDERICO L. MAGPANTAY, JR.
Judge Advocate General’s Office (JAGO)
Page | 102
Re: Complaint of Ms. Jelly P. Evangelio vs. PO2
Orlando C. Borromeo (AFP/BOS 812470/PN

Sir:

This pertains to the above matter referred to us by Ms. Evangelio


requesting for assistance to make this representations before your
Honorable Office.

According to our client, she was intimidated and gypped by Mr.


Borromeo to execute and sign an affidavit of desistance copy of which
was submitted by the latter before your Good Office in support of his
motion seeking the reconsideration of the resolution rendered by the
Provost Marshall ordering his discharge/dismissal from military
service.

Moreover, our client told us that after her execution of the said
affidavit, Mr. Borromeo again went to her place and threatened her as
follows: “Kung makukulong ako, uubusin ko kayong ipapatay.” This
remark is reflected in the Certification of Blotter, copy of which is
attached as Annex “A” hereof.

Based on the said blotter, our client deemed it necessary to


secure a Barangay Protection Order against Mr. Borromeo, copy of
which is attached as Annex “B” hereof.

In view of all the foregoing, we respectfully request your Good


Office to deny Mr. Borromeo’s motion for reconsideration and/or if the
order for his dismissal from the service has already been recalled/lifted
kindly treat this letter as a motion for reconsideration as the basis for
the recall of the order of dismissal (affidavit of desistance), is void, the
same having been secured from complainant using intimidation, threat
and fraud.

We appreciate your patience in bearing with us and it is our


earnest hope that justice be accorded to our client who is a victim of
violence by a man who is supposed to be a soldier and a gentleman,
mandated to protect the people.

Yours sincerely,

DANNY F. VILLANUEVA

Law Firm of
BACLIG & VILLANUEVA
Unit 204, 2nd Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
21 June 2016
Page | 103
MR. JESSIE ORTEGA REVO
Fun & Sun Resort
Burol Dos, Balagtas, Bulacan

Re: Demand for Compensation/Damages

Dear Mr. Revo:

This pertains to the above demand for compensation by our


clients, the family of Mr. Dexter D. Guce of Pasig City, relative to and
over the hurtful treatment, very poor accommodation, and damages
sustained by them on May 7, 2016 at Fun & Sun Resort.

According to Mr. Guce, to celebrate the birthday of his child, a


once-in-a-lifetime event for parents and supposed to be a joyous and
fun-filled occasion for the whole family and friends, the Guce family
agreed to an event package offered by you consisting of swimming from
3:00 P.M. to 10:00P.M., food, birthday program, accommodation for all
guests and parking for all attendees.

On the day of the event, our clients were surprised to learn that
all the pool areas had also been reserved for other clients, no parking
inside the resort was available, most of the food were no longer fit for
human consumption, the poor accommodation was almost unbearable
and worse, because you directed Mr. Guce to park his car outside the
resort, in the area not intended for parking, the bumper of his car hit a
protruding rock causing damage worth P30,000.

In view whereof, for all the embarrassment, unnecessary stress,


and damages sustained by our clients, we are demanding a
P150,000.00 compensation to be paid within five (5) days from receipt
hereof, otherwise, much to our regret, we shall be constrained to bring
the matter to court and hold you liable for a bigger amount of damages
and all the expenses appurtenant to a court action.

It is our earnest hope that you will avoid costly litigation by


settling the just demand of our clients as above-stated.

Yours sincerely,

DANNY F. VILLANUEVA
Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033 Page | 104
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

17 June 2016

THE HONORABLE CITY ASSESSOR


Quezon City Government
City Hall Complex

Re: Request for Issuance of


Corrected/Amended Tax Declaration of Real
Property No. E-139-03895 0000-2005-10-230503

Sir/Madam:

Warmest regards!

This pertains to the above-stated request of our client, Froilan G.


Clemente, Jr., of Quezon City, to reflect the Transfer Certificate of Title
No. 287579 covering Lot 2, Block No. 16 PSD-34147 with an area of
4,566 square meters, in the new tax declaration issued by your Office.

The above-described property is previously covered by Tax


Declaration No. D-139-11027, Confirming TD 114-21-139-020-001,
and Property Index No. 21-01285 which also indicates TCT No. 287579
as the TCT covering the same.

As afore-stated the new tax declaration issued by your Office has


left out and/or deleted the TCT number embracing the lot, hence, this
request for correction and/or amendment by indicating TCT No.
287579 as the certificate of title embracing the subject lot.

Your prompt action on this humble request will be duly


appreciated.

Yours sincerely,

DANNY F. VILLANUEVA
The Honorable Branch Sheriff
Branch 146, Regional Trial Court
Makati City
Page | 105
RE: THIRD PARTY CLAIM over that property covered by TCT Nos. 004-
2016001556 and 004-2016001557 of the Registry of Deeds of Quezon
City in the name of CHITO PASCUAL

Dear Sir:

It has come to our attention that you have been directed by the
Honorable Regional Trial Court, through an Order dated 20 April 2016,
in Civil Case No. 16-374, to attach the properties of the defendants
therein.

Please take notice that our client, Chito Pascual, represented by


his attorney-in-fact, Mr. Mark G. Enriquez, and not any of the
defendants in the afore-stated case, is the true owner of the above-
described properties. Accordingly, the same should be excluded from
the implementation of the order and if so already attached, the same
should be released and/or discharged pursuant to Section 14, rule 57
of the Revised Rules of Court.

In support thereof, please find the attached Affidavit of Third


Party Claim and other pertinent documents.

We look forward to your immediate attention and action on this


matter.

Yours truly,

DANNY F. VILLANUEVA
Copy furnished:

Atty. Harold Howell Banalagay LBC No.___________


Metropolitan Bank and Trust Company
Metrobank Plaza, Sen. Gil J. Puyat Avenue, Makati City
Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033 Page | 106
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.
19 May 2016

MR. FLOYD H. FURTO


Unit 1130, Victoria Towers C
No. 79 Panay Ave. cor. Timog Ave., Quezon City

Re: Demand to Pay Rental and to Vacate Premises

Dear Mr. Furto:

Warmest regards!

This refers to the above matter referred to us by your Lessor,


Ariel R. Ang, of Quezon City to enforce the terms of the Contract of
Lease dated February 1, 2016.

According to Mr. Ariel Ang, you failed to pay the rentals for the
months of March and April 2016 and that up to this time you have not
paid the electric bill in the amount of P18,000.00. May we call your
attention to the pertinent provisions of the subject contract of lease
which provides and we quote:

“10. That in case of non-payment of the rental herein stipulated, or


violation of any condition of this contract, the lease shall be considered
rescinded, and the lessor shall have the right to demand that the lessee
SHALL VOLUNTARILY VACATE THE PREMISES WITHOUT ANY LEGAL
ACTION.

11. That any and all violation of the condition of this contract shall
subject the guilty party to the payment of damages aside from costs of suit
and attorney’s fees, as the case may be.”

In view whereof, we are giving you five (5) days from receipt
hereof within which to pay the accrued rentals in the amount of
P30,000.00, and to voluntarily vacate the subject premises otherwise
much to our regret we shall be forced to enforce the above-stated
provisions whereby aside from evicting you from the subject
condominium unit you shall also be made to pay interest of the unpaid
rentals, attorney’s fee, damages, and costs of suit.

We will appreciate due and prompt action on this demand.

Yours sincerely,
DANNY F. VILLANUEVA

Law Firm of
Page | 107
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
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Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

30 April 2016

ENGR. GEORGE CORPUZ


Cainta

Engr./Sir:

Warmest regards!

Mr. Froilan Clemente, Jr., has assigned to the Law Firm the
right to receive your payment in the amount of P100,000.00 plus
three (3) percent monthly interest starting February 15, 2016 in
payment of the attorney’s fees due to the Law Firm.

Kindly entrust to Michael Pelayo the above-stated amount.

Thank you very much.

Yours sincerely,

DANNY F. VILLANUEVA

Conforme/At my instance:

FROILAN G. CLEMENTE, JR.


Law Firm of Page | 108
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

26 April 2016

MR. JOE PETER A. SIMEON


President, Imus Business and Technological College
E. Aguinaldo highway, Palico 4, Imus, Cavite

RE: Demand to Pay P2,075,000.00 plus interest

Dear Mr. Simeon:

Warmest regards!

This refers to the above matter referred to us for legal action


by our brother in the Iglesia Ni Cristo (Church of Christ), Engr.
Benjamin dela Cruz of San Raphael, Bulacan.

Your obligation to pay the above-stated amount is based on


the four (4) checks you issued in payment for the construction
materials delivered at your above-addressed school.

We are urging you to pay our brother within ten (10) days
from receipt hereof, otherwise, much to our regret, we shall be
constrained to take appropriate actions including filing of
administrative complaints before the Commission on Higher
Education (CHED), TESDA, and Professional Regulation
Commission (PRC) in addition to applicable court actions.

We earnestly hope to hear from you. You can dial our


numbers or you can visit our office any day within office hours.
Yours sincerely,

DANNY F. VILLANUEVA
Page | 109
Law Firm of
BACLIG & VILLANUEVA
nd
Unit 204, 2 Flr., Eagle Court Condominium, No. 26 Matalino St., Central Diliman,
Quezon City; Tel. Nos. 9204710; 0927-619-1033
--------------------------------------------------------------------------------------------------------------------------------------------
Judge Vivencio A. Baclig (Ret.)
Atty. Danny F. Villanueva, Ph.D.

19 November 2015

HON. CLARO A. ARRELLANO


Prosecutor General
Department of Justice
Padre Faura St., Malate, Manila

RE: Opposition to Atty. Roque’s Request for Transfer of Venue of


Re-investigation in I.S. No. III-03-INV-15H-00428

Sir:

Warmest regards!

We start this letter by noting that in the Request for Transfer


of Venue of Re-investigation dated October 30, 2015 made by the
Law Firm of Roque & Butuyan, complainant emphatically
declared that he “has faith and confidence in the Office of the
Provincial Prosecutor” of Bataan to conduct and complete the re-
investigation in accordance with the Order of the Presiding Judge
of Branch 5 of the Regional Trial Court of Dinalupihan, Bataan.

The subject request lacks factual and legal bases. That the
Senior Partner of the Law Firm handling the case for the accused
had been, twenty (20) years ago, assigned as judge of the Regional
Trial Court in Bataan, thus, “may have an impact—no matter how
insignificant—in the re-investigation” is to allow one’s imagination
to wallow and wander beyond the moon and the stars or even the
heaven of heavens. The imagined influence is far too remote
considering that the said stint of Atty. Baclig as Presiding Judge
of the Regional Trial Court of Bataan was too short and had
ended almost twenty (20) years ago.
Also, the proposed transfer of venue of the re-investigation
would violate the Order of the Court for the Office of the
Provincial Prosecutor of Bataan to FINISH AND COMPLETE THE
RE-INVESTIGATION WITHIN A PERIOD OF THIRTY (30) DAYS.
(Vide: attached Order of the Court). Page | 110

Most humbly, unless and until the said order of the Court is
recalled and/or set aside, this Honorable Office is bound by and
must abide the same. There is simply no compelling and
overriding reason to grant the subject request.

Our deep and sincere appreciation for the ever unflinching


impartial and speedy administration of justice by the Department
of Justice.

Respectfully,

The Law Firm of


BACLIG & VILLANUEVA
Counsel for Engr. Arsenio P. Maranan

By:

DANNY F. VILLANUEVA

Cc:

Provincial Prosecutor, Balanga Bataan


Presiding Judge, Branch 5, Regional Trial Court
Dinalupihan, Bataan

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