ZAFRA LAW OFFICES

ATTY. JOSE P. ZAFRA IV, R.M.T

Tandag City, Surigao del Sur 8300
Cel: 09224309694  09778531682  Tel: 086-211-3216
Email Add: josepzafraiv@yahoo.com

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To: SAMUEL TRABEL TUBO 16 January 2020

Purok 2, Capandan, Cortes
Surigao del Sur

Purok Paradise, Brgy. Telaje

Tandag City, Surigao del Sur

SUBJECT: DEMAND LETTER

Dear Mr. Tubo:

I am the counsel of your wife, Elma Paimalan Tubo, who is also the mother of your two
children, namely: Mary Kay P. Tubo and Sheena Marie P. Tubo.

We are writing this letter to formally demand support from you.

My client is asking for a monthly support of Php 15, 000.00, payable at the beginning of
each month. This amount will be used by my client to pay the expenses of her and your
daughter, Sheena Marie’s basic needs such as food, allowance and her tuition and other
school fees.

Support, as defined by Article. 194 of the Family Code, comprises everything

indispensable for sustenance, dwelling, clothing, medical attendance, education and
transportation, in keeping with the financial capacity of the family.

The education of the person entitled to be supported referred to in the next preceding
paragraph shall include his schooling or training for some profession, trade or vocation,
even beyond the age of majority. The same Article also explained that transportation shall
include expenses in going to and from school, or to and from place of work.
Please take note that the amount being demanded by my client may change in the future
depending on your daughter’s needs.

I would also like to inform you that an unreasonable deprivation of your child’s basic needs
is a criminal act. It is considered as an act of child abuse as defined under Sec. 3. b(3) of
R.A. 7610, also known as Special Protection of Children Against Child Abuse,
Exploitation and Discrimination Act. It states:

"(b) "Child abuse" refers to the maltreatment, whether habitual or not, of the child which
includes any of the following:

(1) xxx
(2) xxx
(3) Unreasonable deprivation of his basic needs for survival, such as food and shelter;”

In addition, it is also a violation of Republic Act 9262 or the Anti-Violence against Women
and Their Children.

Please contact me or visit my office within 10 days from receipt of this letter, otherwise,
we will be forced to file the appropriate civil or criminal cases against you.

Truly yours,

Atty. Jose P. Zafra IV, RMT

Counsel for Elma P. Tubo