DE GUINO-ROYANDOYAN LAW OFFICE

(Unit 415) 3650 Davila Street, Makati City

Telephone No. + 63 2 823 1510

February 4, 2016

MRS. LETICIA H. FLORES

Lot 13 Block 51 Town and Country
Subdivision, Dasmariñas, Cavite

Mrs. Flores,

This has reference to the property owned by Maria Aurelia A.

Cuyugan which you are currently occupying.

By way of background and to refresh your memory as well,

sometime in the year 2007 or thereabouts, Ms. Cuyugan bought the real
property located in Lot 13 Block 51 Town and Country Subdivision,
Dasmariñas, Cavite. Because of your personal and intimate relationship
with Ms. Cuyugan during that time, she entrusted you with the money to
pay for the house and lot. It was not unknown to you that it was Ms.
Cuyugan who paid for the entire purchase price of the property. This can
be proven by the regular remittances from her to your bank account.

Upon full-payment of the property, Ms. Cuyugan was unable to

personally process the property title and the tax declaration. Ms. Cuyugan
has been living in the United States and is visiting the Philippines only
once every year or so. With full trust and confidence in you, the title to the
property was placed under your name and Ms. Cuyugan’s to facilitate the
property titling and payment of taxes. You and your three children were
also given the authority to live in the house, with occasional visits from Ms.
Cuyugan when she will be in the country.

However, sometime in 2009, your personal and intimate relationship

with Ms. Cuyugan turned sour and you eventually separated. This
prompted Ms. Cuyugan to ask her relatives to get you out of her house, but
to no avail.

Efforts were made to reach out to you in a civil manner. You even
had a meeting with Ms. Cuyugan’s mother sometime in 2015, before the
Town and Country Subdivision homeowner’s association officers, where
you agreed that you will obtain a loan and surrender the property back. It
has been a year and still no action from you.
 For almost ten years now, you and your family have been living in
the house and enjoying a property that is not even yours in the first place.
For that very long period, the real owner and her family have been
deprived of a property that is rightfully theirs.

Hence, at this point of saturation, not only does Ms. Cuyugan want
her property back, she is also demanding the equivalent amount in pesos
of the period when she was deprived of her right to use the property
(prevailing rental rate x 12 months x at least 6 years), which is approximately
Seven Hundred Twenty Thousand Pesos (Php720,000.00).

Assuming arguendo, that you equally share the same right with Ms.
Cuyugan over the subject property, please note that you still deprived Ms.
Cuyugan of her equal share thereof by giving no access to her whatsoever
or a key to the house, reckoning from 2009 onwards. There is a
corresponding monetary equivalent to that as well.

Moreover, please be informed that Ms. Cuyugan will be in the

Philippines anytime soon and is looking at filing the cases of estafa and
sexual harassment against you. You know very well that you have had
intimate relations with her when she was your student at sixteen years old
which is a clear case of sexual harassment. While your relationship
continued even after she reached the age of majority, you falsely pretended
to love and care for her, and used that relationship to have her support you
and your children financially. Ms. Cuyugan has generously sent money to
you on a regular basis to finance your daily sustenance and the education
of your children, all evidenced by her bank records.

Based on the foregoing, demand is hereby given for you to pay the
amount of Php720,000.00 and to turn over the premises to Ms. Cuyugan,
through the undersigned, within thirty (30) days from receipt hereof.
Should you fail to comply within the period provided herein, Ms. Cuyugan
shall be constrained to file the appropriate civil and criminal cases to
protect her interest.

Should you be ready with the payment and to comply with the
conditions hereof, kindly contact the undersigned the soonest possible
time.

Atty. Angela Kristine D. Royandoyan

Counsel for Maria Aurelia Cuyugan
+63 915 6608616