23 September 2019

MR. DEREK RAMOS

No. 2 Bagumbayan,
Iba, Zambales

Subject: Demand Letter for Sum of Money

My client, Mr. Pepe Smith, a resident of No.1 Bagumbayan, Iba, Zambales,

complained that you failed to settle your obligation in full. Based on the surrounding
antecedent facts narrated by my client, are as follows, to wit:

On 3 November 2017, my client entered into a lease agreement with you in utilizing,
for residential purposes, the house located at No. 2 Bagumbayan, Iba, Zambales
and subject to rental payments of Five Thousand Pesos (PhP 5,000.00) per month.
However, drafting a clear, written lease agreement was dispensed with whereby you
were allowed to enter and stay on the property out of the generosity of the owner.

But starting 11 June 2018, Mr. Smith has not received your full monthly rent
payments. Moreover, you have remodeled/converted the house into a bar which
resulted to property damage. It would require Five Hundred Thousand (PhP
500,000.00) to restore the house to its former condition.

In my presumption, the surrounding facts narrated and based on the pieces of

evidence that my client produced, you are bound to pay the process of the lease
according to the terms agreed upon, to use the thing leased as a diligent father of a
family; and to pay the expenses for the deed of lease (Article 1657, Civil Code of the
Philippines). Failure on your part to comply with the obligation shall give the other the
right to perform all the remedies provided by law.

As my client believes that he has an action or a right to deprive another of

possession (in this case, the lessor) he will invoke the aid of the competent court if
the possessor refuses to yield. As such, will be forced to file a case for Unlawful
Detainer against you in any of the Metropolitan Trial Courts (MTCs) of the place
wherein my client’s property is located.

Further, Section 9 of Republic Act (R.A.) No. 9653 or the Rent Control Act of 2009
provides:
“Section 9. Grounds for Judicial Ejectment. Ejectment shall be allowed on the
following grounds:
Arrears in payment of rent for a total of three (3) months: Provided, that in the case
of the refusal by the lessor to accept payment of the rent agreed upon, the lessee
may either deposit, by way of consignation, the amount in court, or with the city or
municipal treasurer, as the case may be, or barangay chairman, or in a bank in the
name of and with notice to the lessor, within one (1) month after the refusal of the
lessor to accept payment.”

I therefore kindly request that the outstanding balance be paid immediately and that
you ensure that all future rental payments be made in full on the due date.

Further, in light of the circumstances, your actions have caused my client to suffer
emotional distress and the severity of the shock upon learning of the said
developments, resulted in a heart attack which occurred as soon as he arrived from
his Maldives trip on 3 August 2018. His condition required him to be hospitalized for
50 days due to heart surgery and rehabilitation. Because of the great pain and
suffering this has caused, the client demands compensation for the payment of
medical expenses totaling to PhP 500,000.00 to include doctors’ charges and
prescription medication. He would appreciate if negotiations can commence for the
settlement of his claim.

Due to my client’s current state of health, he has designated Myra E who will act as
his representative in matters dealing with the presenting concerns.

Accordingly, demand is hereby made upon you to pay the amount of PhP
1,000,000.00 directly to my client within FIFTEEN (15) days from receipt of this
letter. Otherwise, I will be constrained to file the necessary legal action against you to
protect my client's interest without further notice.
I look forward to resolving this matter quickly. You may contact me at the above
number if you have any questions or need additional information. Thank you for your
co-operation in this matter.

Respectfully yours,