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Suite 308 3/F Laperal Building

Session Road, Baguio City
2600 Philippines
Telefax (083)552-5627
Email : Fgt@gmail.com

17 February 2017


No. 23 Mapukpukaw Street
Dimasarakan City



Vice Chairman





I write on behalf of my client, MR. JUAN LAKAD, former business affairs manager
of Lupa Realty, Incorporated (LRI), in relation to LRIs outstanding civil obligation in the
amount of Php15,000,000.00, exclusive of interests, by virtue of LRIs Board Resolution
No. 01, Series of 2008 (attached herewith as Annex A).

LRIs Board Resolution No. 01, Series of 2008, signed by all officers of the
corporation,1 indubitably shows LRIs obligation to deliver to my client, in lieu of the
aforementioned civil obligation, the following properties:

1. Two (2) corporate shares of Pang-ur Golf and Country Club (PGCC) with an
estimated value of P4,000,000.00 computed at P2,000,000.00 per share;
2. Units 1, 2 and 3 of Margaay Condominium (MC), each unit with an estimated value
of P2,000,000.00; and

1 The Board Resolution did not go through stockholders votes as it was determined and admitted at the time
by the chairman of LRI, Joyce Jones, that the indebtedness to my client amounted to only 10% of the
corporations total assets, which was Php150,000,000.00. Further, it was admitted that the corporation had no
3. Five (5) hectares of agricultural land located in Liblib, Suli with an estimated value of

Shortly after the passing of said Board Resolution, my client tendered his resignation
as business affairs manager of the corporation on the supposition that the properties as
aforementioned were properly delivered to him. However, my client has confirmed that LRI
has actually failed and continues to fail and/or refuse to properly deliver/transfer the
aforementioned properties to his name, despite repeated demands for LRI to do so.

Specifically, my client has informed me that (1) the corporate books and records of
PGCC do not reflect the transfer of shares of the PGCC to my clients name, which threatens
his continued use of PGCCs facilities; (2) Unit 1 and 2 of MC have tenants which refuse to
vacate the respective units, and which prevent my client to actually occupy the said units; (3)
upon verification, not only is Unit 3 of MC not yet transferred in the name of my client, it is
actually already in the name of another corporation, and not of LRI, the same having been
sold to Laos Corporation on 30 November 2004; and (4) TCT No. 03 has not yet been
actually transferred to my clients name, despite my clients continued undisturbed
possession of the land covered by TCT No. 03 since 2009 and which threatens the
improvements already built by my client thereon in the amount of Php3,000,000.00.

It is unfortunate that LRI continues, without any valid reason, its contumacious and
abject refusal to properly deliver the aforementioned properties to my client. Worse, one of
the properties was even sold to another corporation without my clients knowledge.

LRIs pretenses of delivering the properties were the primary reason why my client
decided to resign as business affairs manager of the corporation, and had he known that the
properties would not be delivered, he surely would not have resigned from his position and
continued to accumulate just compensation for his services. Furthermore, damage is wrought
and will be wrought by my client because of the continued threat upon the enjoyment of my
client relative to the above properties which he currently possesses and the improvements
he had already introduced.

Given the aforementioned specific failures of LRI, demand is made, at this time, to
deliver/transfer to my clients name:

a. Relative to the corporate shares of PGCC, the number of shares corresponding

to the fair market value of Php4,000,000.00 at the time of the complete delivery
of the shares;
b. Relative to Units 1, 2, and 3 of MC, the condominium titles of the units free from
any liens and any informal occupants therein;
c. Relative to the five (5) hectares of agricultural land in Liblib, Suli, Transfer
Certificate of Title (TCT) No. 03; and
d. Interest rate of 6% of the monetary amount of Php15,000,000.00 from date of
passing of the Resolution until full satisfaction of the delivery of the
aforementioned properties, in lieu of damages,
with all costs and fees of transfer and necessary legal process to effectuate the same
to be borne by LRI.

In the alternative and for ease of facility, my client is also amenable for LRI to pay
him the amount of Php15,000,000.00, plus 6% annual interest from 31 December 2008 up
to full satisfaction of the amount. Please note that the amount is already a discounted amount
that my client has favorably granted LRI.

In light of the foregoing, FINAL DEMAND is hereby made upon you to

deliver/transfer the aforementioned properties to my clients name in the manner as
aforestated with the concomitant interest rate or, in the alternative, pay my client the amount
of Php15,000,000.00 plus 6% annual interest from 31 December 2008 up to the full
satisfaction of the amount representing my clients unpaid salaries and account receivables
from the corporation from 1995 to 2008. Otherwise, my client will be constrained to institute
the appropriate actions against you to protect his interests and vindicate his rights.

Please be guided accordingly.

Very Truly Yours,