27 January 2021

Atty. FREDERICK FERMIN H. MAGTIBAY

Head, Litigation Department
FF MAGTIBAY LAW OFFICE
53-3C AL3 Bldg. #53 Visayas Ave.
Brgy. Vasra, Quezon City

Re FORMAL DEMAND OF PAYMENT, DATED 20 JANUARY

: 2021

Dear Atty. MAGTIBAY:

We write on behalf of Ms. ELEANOR BOHOLANO MERCADO and in

response to your Formal Demand of Payment, addressed to our client, dated 20
January 2021, essentially warning our client that failure to pay the outstanding loan
amount, as indicated in the said Formal Demand of Payment, will constrain your
client to file criminal actions for estafa and violation of the bouncing checks law.
Your client is also contemplating in filing the appropriate civil case.

Firstly, it would be favorable to our client if she would receive notices from
this address: Block 12 Lot 41 Acacia St., R. Magsaysay Avenue, Calendola
Village, San Pedro, Laguna.

It was relayed to us that when our client first contracted the loan obligation,
her business venture then went insolvent and bankrupt, resulting in extreme and
serious financial difficulties on her part. While she was very much willing to settle
her obligations, her finances said otherwise.

As response thereto and as intimated to us by our client, it has to be noted

that our client never received any notice of dishonor or any other notice which
would inform her that the check/s she previously issued bounced or was drawn
against insufficient funds. This gave the impression on our client that her monetary
obligation has been satisfied or, at least, settled by your client.

We would like to reiterate that our client recognizes her monetary obligation
in favor of your client, and is willing to satisfy such obligation. However, our
client would like to seek for your client’s compassion and indulgence, given the
foregoing, and the fact that we are currently suffering from this global pandemic.
Also, our client is currently unemployed for a long time, which might hamper her
ability and capacity to pay the same.

In view of the foregoing, our client would like to seek for a payment scheme
which would lessen the financial burden of satisfying her monetary obligation,
including, but not limited to, the waiver of any penalties and surcharges, and
lessening, if not eliminating, the interest over the principal loan amount, or having
the same be satisfied on installment terms. If it would not be too much for your
client, maybe our client may also ask for the restructuring of her loan obligation to
lessen the burden of paying the same. Our client rest assures that she will satisfy
her obligation, albeit, she might need a sufficient amount of time to do so.

For your consideration.

Very Truly Yours,

Atty. DARWIN S. VIADUMANG

Roll No. 73039