You are on page 1of 2

18 March 2016

UNITED PACIFIC RISE CORP.


Building 2 Philippine Veterans Industrial Compound
Western Bicutan, Taguig City

Attention: Mr. CHUA PING HIAN


President

SAMUEL DOMINGUEZ DE TORRES


21 Quirino Avenue, Z6, Signal Village
Taguig City

Re: Demand to Pay for Damage to Honda CRV


With Plate Number XFD 383
-------------------------------------------------------

Gentlemen:

We write on behalf of our Client, NADINE H. FANLO, in relation to the damage


incurred on our Clients vehicle, a 2009 Honda CRV with Plate Number XFD 383
(Subject Vehicle) when your vehicle, a 2010 Mitsubishi L300 with Plate Number
NQW 134 (Mitsubishi), driven by Samuel Dominguez de Torres (Mr. de Torres),
while violating traffic rules and regulations, collided with the Subject Vehicle on 26
January 2016 at around 3:55 p.m. at the intersection of J.P. Rizal Avenue and Gonzales
Street, Barangay Guadalupe Viejo, Makati City, Metro Manila.

As you are well aware, our client was carefully driving the Subject Vehicle along
Gonzales Street from Conrado Street towards J.P. Rizal Avenue, when your driver, Mr.
de Torres, drove the Mitsubishi on the counter flow lane as it overtook the vehicles on
the left side and collided against the Subject Vehicle, to our Clients damage and
prejudice.

Our Client previously informed you that the estimated damage on the Subject Vehicle
amounted to around Ninety-Three Thousand Six Hundred Seventy-Two and 79/100
Pesos (Php93,672.79), without prejudice to actual costs for repair of said damage.

A copy of the Estimate for the repair of the Subject Vehicle is attached hereto as Annex
A and made an integral part hereof.

Our client has made numerous attempts to discuss and amicably settle the matter with
your office, to no avail. It bears stressing that earnest efforts were exerted on our clients
part to amicably settle the matter with you, but the same fell on deaf ears. Worse,
despite our repeated demands, the outstanding obligation, to date, remained unpaid.

In a Letter dated 12 February 2016, our Client sent you their formal demand for you to
settle, through your own or your insurance company, your obligation of repairing the
Subject Vehicle and for shoulder any and all costs as may be necessary and incurred in
connection with the repair of the Subject Vehicle with Honda, within five (5) calendar
days from notice of this letter.

On 24 February 2016, your representative, HR Officer Mikko Precilla, called our Client,
acknowledging your obligation to our Client and undertaking to settle the matter
through your insurance company the following week. To date, however, your
outstanding obligation remains unpaid, to the prejudice of our Client.

Thus, final demand is made upon you to settle, through your own or your insurance
company, your obligation of repairing the Subject Vehicle and to shoulder any and all
costs as may be necessary and incurred in connection with the repair of the Subject
Vehicle with Honda, within five (5) calendar days from notice of this letter. Should you
fail to settle the aforementioned obligation within the said period, we will be
constrained to institute such appropriate actions against you, including but not limited
to civil, criminal, and administrative actions, with additional claims for damages,
attorney's fees and other expenses of litigation to protect our Clients interest.

We trust that you will give this matter your preferential attention.

Very truly yours,

JOSE ANTONIO ALILING & ASSOCIATES

By:

JOSE-ANTONIO T. ALILING

FRANCESCA LOURDES M. SEGA

You might also like