APOLLO X.C.S.

SANGALANG & ASSOCIATES

P A L A D I N S O F L A W_

th

5 Floor Builders Center, 170 Salcedo Street, Legazpi Village

Makati City, Metro Manila, Philippines 1229
Telephone: (+63 2) 209-3568; (+63 2) 208-2606; Mobile: (+63 917) 821-6848
Email: apollo.sangalang@lawyer.com
January 30, 2015

Homeowners Association
Baguio Green Valley Condominiums
Baguio City, Philippines
Attn:

Ms. Sally Tee

Re:

Demand to Rehabilitate and Repair Unit 22a and Unit 24 and/or Cease and desist
from deducting association dues from the advances made by Mr. Wong.

Gentlemen:
I write on behalf of our client, Mr. Steven Wong. Our client is the owner of two (2) condominium units, in
Green Valley Condominium in Baguio City.
Based on our client's records, he has been a unit owner and association member in good standing. Mr.
Wong oftentimes pays his monthly association dues in advance of at least five years.
Sometime in 2014, our client plans to renovate the interior part of his unit in building A for the upcoming
Holy week vacation, however it came to his attention that aside from his unit, unit 22 A, an adjacent unit, is
dilapidated which prevented our client from renovating his unit. For this reason, our client looked for the advice of
a professional engineer thus, he was advised to have the outer wall of unit 24 A and unit 22 A repaired and
rehabilitated first before renovations would be applied for his unit.
Furthermore, the association records would reveal that the registered unit owner of 22 A, Theresa
Ramos, had not been occupying the said unit for more than a decade. There was never a single communication
received by the association nor the management office from her informing of her whereabouts and contact details.
Thus, her absence for more than 10 years costs the deterioration and degeneration of her unit thus, making the
unit hazardous not only to its adjacent units but also to the entire building.
On March 15, 2014, our client wrote a letter requesting that he be allowed to repair unit 22 of building A.
Apparently, the letter of request landed on deaf ears, because of this, our client was deprived of repairing and
renovating his unit. This deprivation was tantamount to dispossession. It deprived our client the opportunity to use
and utilize his property, deprived him of possible income in the amount of 1,500 pesos/day or 547,500/year of
income if he desires to have his unit rented/leased.
In fact, there is a practical solution to prevent future harm among the members of the association. Our
client, is willing to shoulder the cost of the repair, rehabilitation and maintenance of unit 22. This is for the sole
purpose of preserving the integrity of unit 22 and building A from further deterioration for the safety and protection
of our client and members of the association from possible future harm.
In case that the association would allow our client to make the necessary repairs and rehabilitation if unit
22 A, our client asks that he be allowed to occupy unit 22 of building A in lieu of the costs of repair and
rehabilitation. In addition, our client will be responsible for the association dues and flat rate of water charges of
the said unit subject to reimbursements upon the return of the unit owner or her heirs and assignees.
Furthermore, our client guarantees that, if and when Mrs. Ramos or her duly authorized representative returns

and reappears to claim the subject unit, our client will dutifully comply in ceasing possession of the said unit and
to return the same in order.
Considering the cost of repairs and expenses, as may be incurred if our client, he requests that he be
entitled for the full reimbursement of the following 1. Association dues paid in advance for the benefit of unit 22 of
building A, 2. Flat rate of water charges for the said unit, 3. Construction and repair expenses plus 1.5% interest
per month compounded if not yet fully satisfied by the said unit owner.
Should the Association deny the above requests, it is legally demandable that the Association would
cause the repairs of unit 22 A including the common areas such as the outer wall of the hallway and its
maintenance to prevent further damage and injury. Otherwise, our client is inclined to demand that you cease and
desist from deducting the association dues given in advance by our client and to pay 1500/day of possible income
loss unless and until repairs and maintenance as demand is accomplished.
Our client firmly knows that under the Condominium Act and the contract between the unit owner and the
Association, dues paid by members are for the very purpose of maintaining the building that they occupy. It is an
expense on their part for your organization to administer and maintain.
Otherwise, I shall immediately file a complaint in violation of R.A. 4726 or otherwise known as the
Condominium Act of 1966 against you with claims for actual damages, moral damages, exemplary damages,
fines, costs of suit, interests, penalties, etc., which based on my rough estimate would be an additional Php
1,000,000.00 on top of the above-quoted amount.
Note that you have been duly warned and notified.

ATTY. APOLLO X.C.S. SANGALANG