A.L.

Law Firm
Block 4 Lot 11, Greenwood Sub., Daet, Camarines Norte 4600
Contact No. 0999888444

September 20, 2020

ATTY. ELJAYJOSE M. BARRAMEDA

No. 31 Bagumbayan Sur
Naga City 4400

Fellow Master of the Law practice:

This letter refers to the one you wrote Dating July 28, 2020, that of which was a reply from the
original letter I wrote to Mr. John Doe, and to Mr. John Doe, regarding the Vehicular Accident
that happened at the date of May 11, 2020.

It is to my proper knowledge that the two, of which I wrote my original letter to, is eligible and
should comply with the principle of subrogation.

According to client whom Fortune General Insurance Corp (FGIC) covered, even though the
truck was on its proper lane, the truck driver clearly knew the presence of the Isuzu MU-X upon
overtaking, which was done when the latter honked twice with the former returning the same
amount of honks before the accident happened.

Secondly, according to Mr. John Doe, driver of the black MU-X, there were no agreements done
between the two concerning repairs to their respective vehicles, and that the truck simply
ignored the Isuzu MU-X after the accident by driving away as if nothing happened.

Third, knowing the fact that the driver knew about the presence of the Isuzu MU-X, Sec. 2 (a)
par. 1 of the Insurance Code of The Philippines becomes null as it only applies to “loss, damage
or liability arising from an unknown agent.”

The paragraphs above supports the fact principle of accion in rem verso was be violated, for
according to one of its requisites (c), “The enrichment must not be justifiable”. Knowing the fact
that the truck driver willfully and consciously struck the Isuzu MU-X, he becomes liable under
Article 20 and Article 21 of the Civil Code of the Philippines, resulting for the Principle of
Subrogation to be justifiable upon them committing a violation.
Thank you for your time, and have a good day.

ATTY. ALDRIX LEVY F. AURO