Unit 15, Star Arcade, C.V. Starr Avenue,
Philamlife VillageLas Pinas City 1740 Philippines
Tel/Fax: (63 2) 8725443 & 8462539; Mobile: (63) 943 3425978
Email: email@example.com; cc: firstname.lastname@example.org
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January 28, 2016
Via LBC Express Corp.
Counsel for xxx
xxx Law Office
xxx Ave., xxx
RE : YOUR DEMAND LETTER, DATED JANUARY 22,
2016, ADDRESSED TO xxx.
We represent xxx, a resident of xxx , xxx, xxx City.
This refers to your Demand Letter, January 25, 2016, which the spouse of our client xxx received on January 28, 2016, demanding the sum of P88,424.00 in re: the vehicular incident that happened on January 8, 2016 at about 7:00 AM in xxx, xxx City.
We respectfully DENY the claim of your client, the same being unfounded, baseless and contrary to the truth and the evidence, the truth being that the reckless imprudence, lack of due diligence, and criminal irresponsibility of your client were the proximate cause of the said vehicular incident which likewise caused damage to the vehicle of our client in the amount of P96,480.82 (See attached Toyota Alabang estimate/quotation, dated January 8, 2016).
The said amount of damage shall be proven in due time by our clients before the Office of the City Prosecutor and the proper Trial Court.
Per latest inquiry by xxx, the PNP xxx City Traffic Bureau has forwarded to the Office of the City Prosecutor the records of the said vehicular incident for regular preliminary investigation. The case is reportedly docketed as I.S. 16A-xxx before the said Office and will still be raffled to an investigating prosecutor as of today.
Our clients are prepared to LITIGATE their claim before the said Office and the proper Trial Court of xxx City in due time, without prejudice to the right of the contending parties to discuss and explore a possible Compromise during the Mediation and the Judicial Dispute Resolution phases of the said case.
For your information, xxx will fly tomorrow for abroad as an overseas Filipino worker (a seaman in a foreign cruise liner). His wife, xxx (who is the registered owner of the xxx vehicle involved in the aforecited vehicular incident), will represent him as his attorney-in-fact for purposes of the litigation of the aforecited case before the Office of the City Prosecutor and the proper Trial Court.
Please note that we had previously send a Letter, dated January 8, 2016, to your client xxx, with address of record as per his Driver’s License at xxx, xxx City, inviting him to a conference at our law office on January 13, 2016 at 3:00 PM to discuss/explore a Compromise. Your client did not appear during the said conference. Thank you.
Very truly yours,
Atty. MANUEL J. LASERNA JR.
Counsel for Spouses xxx
Spouse of xxx
And the Registered Owner of
The xxx Family Vehicle
(Toyota xxx, Plate No. xxx)