Legal Writing - Reply Letters

DOMETITA LAW OFFICE
No. 2 Zone 1 Brgy. San Juan, Camaligan, Camarines Sur 4401

Mobile No. 0917-5116242 | Email Add.: dometitalaw@gmail.com
September 20, 2020
ATTY. ELJAYJOSE M. BARRAMEDA

No. 31 Bagumbayan Sur
Naga City, 4400
Dear Atty. Barrameda,
This is in response to your letter dated July 28, 2020 regarding your answer for our client, Fortune
General Insurance Corporation (FGIC), regarding the vehicular accident that happened last May 11,
2020.
We appreciate and understand your views in terms of the Principle of Subrogation. You are correct
in pointing out that my client is an insurance company primarily existing to assume the risk of our
insured clients. However, subrogation is the substitution of one person or group by another in
respect of a debt or insurance claim, accompanied by the transfer of any associated rights and
duties. It is a legal right held by most insurance companies to legally pursue a third party that caused
an insurance loss to the insured.
Furthermore, my client in no way violate the Principle of Unjust Enrichment because FGIC is just
stepping into the shoes of the policyholder and thus will have the same rights and legal standing as
the policyholder when seeking compensation for losses. The compensation
In the case at hand, my client’s policyholder which is the owner of the Black Isuzu MU-X agreed to
pay for the damages sustained during the accident. My client’s policyholder then seeks
reimbursement from my client as their insurance provider. It is part of my client’s function to pursue
a subrogation claim against the party at fault for the loss, which is in this case, your client.
I hope you we make everything clear regarding the concern your raised in your reply letter. My client
and I wish to extend our gratitude for your understanding regarding this matter.
Very truly yours,
ATTY. MICHAEL B. DOMETITA

DOMETITA LAW OFFICE
September 20, 2020

Naga City, 4400
This is in response to your Final Demand Letter sent to my client last August 17, 2020 regarding the
demand for refund amounting to P58,990.00.
My client would like to extend his apology for the misunderstanding regarding the laptop your client
bought last July 19, 2020. It is with great understanding that my client does not mean to cause any
harm or delay in whatever business your client has, hence, we want to reiterate our policy in terms
of replacement of products which were allegedly bought as defective from my client’s store.
In general, the business entitles the buyer to choose any of the following alternative remedies: (a)
repair of the product, in whole or in part; (b) replacement of the product with a like or equivalent
product; (c) refund of the purchase price of the product less a reasonable allowance for use; or (d)
payment of reasonable damages.
Replacement of defective units may take some time due to the limited stock of units they have in
their inventory. Due to this pandemic, delivery of products to and from the store is challenging as
the government imposes strict border controls all over the country. The issue with regards to the
replacement of a lesser model is due to the limited availability of stocks in the store. The store can
only replace the alleged defective unit with those available units at hand. My client allows refund of
the purchase price of the alleged defective laptop; however, it would be refunded with a deduction
for a reasonable allowance for use.
I would like to make it clear that my client is amenable with the above-cited remedies, however,
your client must present to us the official receipt as proof of the sale transaction. We are more than
willing to discuss this matter at hand with you and your client. In this regard, we would like to invite
you for a short conference to discuss and settle this matter once and for all for the benefit of both
parties.
Thank you for your usual understanding.
Very truly yours,

DOMETITA LAW OFFICE
September 20, 2020

Naga City, 4400
This is in response to your Demand Letter sent to my client last July 21, 2020 regarding the alleged
unjust enrichment charges brought about by the company billing to your client as of June 16, 2020.
We would like to apologize for the stress this case has caused upon your client. However, it should
be noted that our billing statement is a reflection of the client’s usage of our services. Although your
client has already reported several cases of NO SERVICES/NO INTERNET CONNECTION, the usage
incurred by your client will still be billed.
This case is better discussed by showing to your client the usage recorded in the system of my client.
With that, may we invite you and your client for an informal conference to discuss the case and
settle any obligation, should anything arise.
We are more than willing to help your client settle this case in the most convenient way possible.
Rest assured that we will also do our part to fully explain our side during the conference.
Thank you for your usual cooperation.
Very truly yours,

DOMETITA LAW OFFICE
September 20, 2020

Naga City, 4400
This is a response to your letter dated September 20, 2019 regarding your client, The Contractor, his
claim to recover damages from his contract with the Department of Public Works and Highways, 3 rd
District.
We understand your client’s concern regarding the delay in the payment as stipulated in the
contract. We also acknowledge the intent of your client in claiming damages as well as the
cancellation of the contract. However, based from the 2016 Revised Implementing Rules and
Regulations – Annex “I”, Section IV, it stipulated in there the proper procedures for the termination
of contracts.
One of the requirements for the termination of the contract is a letter from your client stating their
intent for the termination. As of this writing, my client has not yet received a formal letter stating
their intention to terminate the contract, hence, we cannot proceed with such.
It is therefore recommended that the terms of the termination of contracts be followed in order for
us to formally proceed with the termination.
Thank you for your usual understanding.
Very truly yours,

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DOMETITA LAW OFFICE

No. 2 Zone 1 Brgy. San Juan, Camaligan, Camarines Sur 4401

September 20, 2020

ATTY. ELJAYJOSE M. BARRAMEDA

Dear Atty. Barrameda,

Very truly yours,

ATTY. MICHAEL B. DOMETITA

September 20, 2020

ATTY. ELJAYJOSE M. BARRAMEDA

Dear Atty. Barrameda,

Thank you for your usual understanding.

Very truly yours,

September 20, 2020

ATTY. ELJAYJOSE M. BARRAMEDA

Dear Atty. Barrameda,

Thank you for your usual cooperation.

Very truly yours,

ATTY. MICHAEL B. DOMETITA

September 20, 2020

ATTY. ELJAYJOSE M. BARRAMEDA

Dear Atty. Barrameda,

Thank you for your usual understanding.

Very truly yours,

ATTY. MICHAEL B. DOMETITA

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