AFFRAYNA LAW OFFICE AND NOTARIAL SERVICES

Ground Floor De Ramas Bldg., A.A. Berces St., Basud Tabaco, Alba y

(0917) 318 6448 affrayna.lawoffice@gmail.com

July 21, 2023

MS. ANA CAMACHO

Supervisor
PEÑAFRANCIA TOURS & TRAVEL TRANSPORT, INC.
CU-UN Tong Bldg., Concepcion Grande 4400,
Naga City, Camarines Sur, Philippines

Dear Ms. Camacho:

I’m writing on behalf of my client KARYLLE ANN R. DERIT, who purchase a

ticket with your Tabaco Booking station dated July 20, 2023, and was issued a
Bus Ticket No. 2523025 paying a 960.00 bus fare on the same date. She is set
to board your bus on July 21, 2023bound to EDSA Cubao, however, due to a
family emergency, said passenger opted not to proceed with her travel, hence is
requesting a refund of a reasonable amount of her paid bus fare, as her new
schedule cannot be determined to date. To our surprise, your personnel
refused to grant the refund citing the provision of conditions of carriage found
on the reverse page of the bus ticket.

A perusal of said ticket, we indeed found the Non-Refund condition, however,

please be reminded that the Condition of Carriage is a Contract of Adhesion,
and is contrary to prevailing public policy. Moreover, non-refund of the fare
where no services were performed is unjust enrichment that runs afoul of the
basic tenets of fair play.

In light of the foregoing, please reconsider giving the necessary refund to the
above-named passenger, otherwise, we will be constrained to file an
appropriate complaint with a regulatory agency and even resort to court if
warranted.

You may contact the said passenger on her contact number 09956175125 or
the number appearing on the letterhead, to facilitate the sought after refund.

ATTY. ANTHONY F. FRAYNA