12 November 2016

J. E. CAMPOS
-Law Firm-

20Flr. Trevi Tower,

Chino Roces Ave.,
Makati City,
Philippines
+63919 2292 463
jecampos@law.com

ATTY. JAMES R. DIMACULANGAN

12 Flr. Raffles Tower, Edades Ave.
Makati City, Philippines
RE:
ANSWER TO DEMAND FOR COLLECTION OF PAYMENT FOR KAHIT
SAAN
RESTAURANT, INC.
Dear Atty. Dimaculangan:
This refers to your letter dated 5 October 2019 demanding payment of
penalty relative to the alleged delay of renovation works with your
establishment located at 830 Donada St. Pasay City, amounting to TWO
HUNDRED SEVENTY THOUSAND PESOS (Php 270,000.00) as incurred
penalty.
Please be informed that as per paragraph 8 of Section 2: Obligations of
Kahit Saan Restaurant, Inc, in the service contract entered and signed by
your company and my client, it is provided that the Second Party, Kahit
Saan Restaurant, Inc., shall conduct a final inspection upon the
completion of the renovation works at your establishment located at 830
Donada St. Pasay City. Further, paragraph 9 of the same contract
provides that the renovation shall be deemed completed and/or finish
upon the final approval of the second party.
On 28 January 2016, JEUC Construction Firm sent the first notice
requesting your party to conduct initial inspection and another notice
sent 1 February 2016 as final notice requesting final inspection of
completion, both received by Ms. Elma Dimaculangan, your daughter and
of legal age and capacity both on the respective dates as per courier
receipt records of LBC. JCF however did not receive any reply for your
company nor instituted any communication to conduct the said
inspection In order to complete the said contract.
In this connection, JCF will not provide payment for such demand for
penalty considering that the renovation was completed on time and the
cause of the said delay based on the breach of the abovementioned
contract is the failure of your company to conduct the necessary
inspection and sign the acceptance of completion of project on time.
You may speak with our firm for the details of this matter and our party is
prepared to furnish you with the pertinent proofs and documentation for
your perusal.

Very truly yours,

J. E. CAMPOS
-Law Firm-

20Flr. Trevi Tower,

Chino Roces Ave.,
Makati City,
Philippines
+63919 2292 463
jecampos@law.com

ATTY. JOSEF ELVIN U. CAMPOS

Legal Counsel
12 November 2016

ATTY. ELMA B. REYES

Unit 10, 10th Flr. The Fort Legend Tower
31st St. Cor. 3rd Ave.
Bonifacio Global City, Taguig City
RE:

ANSWER TO DEMAND FOR CHILD SUPPORT

Dear Atty. Reyes:

This refers to your demand letter dated 5 November 2016 asking for a
monthly support of SEVENTY THOUSAND PESOS each month from my
Client, Mr. Jonathan Belandrez, in support of their common child.
I am writing to you to inform you that my client has no intention of
abandoning his duties with your common child. However, the financial
support demanded by your client is unjust considering that the common
child remains under shared custody of your client and Mr. Belandrez.
As per the testimony of my client, since their separation in 26 September
2015, the child has remained under custody of both parents to which my
client claims to look after the child on weekdays as compared to the
weekends where the child spends time with your client. Please note that
the child has spent more time with my client, thus conferring that
financial support spent by my client is more than of your client.
Though my client do not intend to cut his support, we are proposing that
instead of SEVENTY THOUSAND PESOS of financial support should be cut
down to a more reasonable and equitable amount. My client therefore
promises to shoulder only haft of the demanded support amounting to
THIRTY FIVE THOUSAND PESOS.
Our firm looks forward to your favorable response to this offer.
Very truly yours,
ATTY. JOSEF ELVIN U. CAMPOS
Legal Counsel

J. E. CAMPOS
-Law Firm-

20Flr. Trevi Tower,

Chino Roces Ave.,
Makati City,
Philippines
+63919 2292 463
jecampos@law.com

12 November 2016

ATTY. ROSE PATIO

Unit 10, 10th Flr. Grand Tower
31st St. Cor. 3rd Ave.
Manila, Philippines
RE:

ANSWER TO DEMAND FOR UNLAWFUL DETAINER

Dear Atty. Patio:

This refers to your letter demanding my client to immediately vacate the
premises of his current residence in view of his alleged failure to pay rent.
As per testimony of my client, his failure to pay for the rent was due to
the absence of neither notice nor verbal notification relative to the
payment of rent. In the instance that you have mentioned in your letter,
the notice which was alleged received by my client was untruthful
considering that on the date mentioned, my client was not staying in the
said premise. Moreover, my client was at her hometown in Batac, Ilocos
Norte, taking care of his bed-ridden mother, thus it is physically
impossible for her to be present in the said date as your client claims.
In addition to this, during the time your client claimed to have sent the
said prior notice, his nephew who is a minor, who presumably received
the notice, failed to transmit the said notice, if it were true.
With this considerations, my client is requesting an extension of the
eviction notice and shall not pay for any penalty fee incurred for the
abovementioned grounds.
Very truly yours,
ATTY. JOSEF ELVIN U. CAMPOS
Legal Counsel