advanced business and legal writing - santos

7/24/2019 Advanced Business and Legal Writing - SANTOS

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Santos Law Offices

#529 KB Arizona Towers, Padre Campa St., Sampaloc ManilaTelefa !"2$ %&5 '()9* Tel. +o. !2%$ &5' ()9"

-mail norman/ennet0santos1mail.comwww.santoslawoffices.com.p0

October 23, 2015

Mr. Butch Cruz

Manila City, Metro Manila

Dear Mr. Butch Cruz,

I am writing to you on behalf of the Ms. Kim Rosa.

I was also informed by my client Ms. Rosa that you have several obligations that are due

and demandable.

!" Child #u$$ort and Cost of Delivery

Ms. Rosa has been seven %" months $regnant with your child. &e are ma'ing a demand

that you $ay half of all cost $ertaining to the delivery of the child and the su$$ort of the child at

the amount of (%,))) $er month after delivery and any other cost the law so $rovides. *rt. !+ of

the -amily Code states,

*rt. !+. #u$$ort com$rises everything indis$ensable for sustenance, dwelling, clothing,

medical attendance, education and trans$ortation, in 'ee$ing with the financial ca$acity of

the family.

/he education of the $erson entitled to be su$$orted referred to in the $receding $aragra$h

shall include his schooling or training for some $rofession, trade or vocation, even beyond

the age of ma0ority. /rans$ortation shall include e1$enses in going to and from school, or to

and from $lace of wor'.2

/he su$$ort shall be due and demandable as of the date in this letter as $rovided in *rt. 3)4 of

the -amily code, which states5 /he obligation to give su$$ort shall be demandable from the

time the $erson who has a right to receive the same needs it for maintenance, but it shall not be

$aid e1ce$t from the date of 0udicial or e1tra60udicial demand.2

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Santos Law Offices



3" Return of (ersonal (ro$erty

&e are demanding the return of three 4" $ersonal $ro$erty you have ta'en from the

a$artment of Ms. Rosa namely5

7ne !" #tandard 8lectric -an,

7ne !" #amsung Mini Refrigerator, and

7ne !" *didas #li$$ers.

9ou are demanded to return the things or its e:uivalent value in the amount of -ifteen /housand

(esos (!;,)))" on or before the 4!stof 7ctober 3)!;. 7therwise we will be constrained to file a

case of estafa against you.


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Santos Law Offices



&e demand that you $ay the amount of /wenty 7ne /housand (esos (3!,)))" as

$ayment for the last three months you have stayed in my client?s a$artment before you left. /his

obligation was brought about by your agreement with Ms. Rosa that you shall be $aying $art of

the rental fees. #uch agreement shall be considered as a binding contract between you and my

client. *s $er the Civil Code, *rt. !4); of the Civil Code as, @aA contract is a meeting of minds

between two $ersons whereby one binds himself, with res$ect to the other, to give something or

to render some service.2

" Cease and Desist -rom arassing

Ms. Rosa has been com$laining that you have been harassing her to return the $earl

earrings you have voluntarily given to her. /he rights over said $ro$erty has been transferred to

Ms. Rosa u$on her receiving of the thing, hence you have no more right over it. 9ou are

demanded to sto$ such harassment activities immediately as they are being done in violation of

the law. *s $rovided under #ec 4 a" and c" of R* +33 or otherwise 'nown as *nti6iolence

*gainst &omen and /heir Children *ct,

a" @vAiolence against women and their childrenE refers to any act or a series of acts

committed by any $erson against a woman who is his wife, former wife, or against a woman

with whom the $erson has or had a se1ual or dating relationshi$, or with whom he has acommon child, or against her child whether legitimate or illegitimate, within or without the

family abode, which result in or is li'ely to result in $hysical, se1ual, $sychological harm or

suffering, or economic abuse including threats of such acts, battery, assault, coercion,

harassment or arbitrary de$rivation of liberty. 1 1 1

C. E(sychological violenceE refers to acts or omissions causing or li'ely to cause mental or

emotional suffering of the victim such as but not limited to intimidation, harassment,

stal'ing, damage to $ro$erty, $ublic ridicule or humiliation, re$eated verbal abuse and

marital infidelity. F 1 12 em$hasis ours"

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Santos Law Offices



My client has the right to remain free from these activities as they constitute harassment and we

will $ursue any legal remedies available against you if these activities continue.

&ith all the foregoing, you are given until 7ctober 4!, 3)!; to com$ly with our

demands. 7therwise, we will be forced to file the a$$ro$riate civil or criminal caseGs against you.

Regards,

SantosK*tty. Horman Kenneth . #antos

&ith my conformity5

KRosaMs. Kim Rosa

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