May 10, 2017

ATTY. ANTONIO D. ARABEJO

Arabejo & Mar Law Firm
Marbella Leisure Plaza
Gallares St., Tagbilaran City

Dear Atty. Arabejo,

This is in relation to the letter you sent to my client, MR. ULDARICO ONG, demanding
him to pay your clients, RICHARD JABINES, ET. AL., the amount of P29,500.00 as a
consequence of a sea accident that occurred on 7 March 2017 involving a motorized
banca.

My client was surprised why he is made to pay for the loss of certain items, damage on
the motorized banca involved as well as the incidental expenses relative to the said
incident when he was not responsible for the incident and he had no contractual
obligation with your client.

My client was not responsible for the accident since the immediate cause were the two
Ocean Jet vessels as reflected in the incident report submitted to the Philippine Ports
Authority of Tagbilaran City. Copy of which is attached hereto for your easy reference.

Also, my client was not the owner of the motorized banca that almost capsized as a
result of the said incident. He was not also its boat captain or member of its crew. He
was just a mere passenger of that vessel just like your clients.

In view of the foregoing, we are sorry to inform you that my client cannot accede to your
demand.

Further, it is our hope that you will not pursue in filing the case against my client since
he has no liability or obligation whatsoever arising from the said sea incident.

Thank you.

Sincerely,

ATTY. DONI D. PIQUERO

Counsel for ULDARICO ONG
51 Remolador St., Tagbilaran City

Upon my request;

ULDARICO ONG