Locsin Bernardo Martin and ASSOCIATES

Attorneys at Law
084 Legis Building, Sampaloc, Manila 1000
Phone (632) 848-0123
lbmlawyers@gmail.com

3 April 2015
Juan Miguel Corporation
Ground Floor, Cattleya Building,
123 Mindanao Avenue, Quezon City
Thru: Mr. Juan Miguel De Leon
President
Mr. Tobi Ocampo
Corporate Secretary
To Whom This May Concern,
Please be advised that our office represents Mr. Manny Y. Pakyaw.
We understand that, from February 23, 2015 up to March 15, 2015, our client Mr. Pakyaw
made several monetary donations to Juan Miguel Corporation(JMC) amounting to Five
Hundred Thousand Pesos (P500, 000.00). The breakdown of which is as follows:
February 23, 2015

P125, 000.00

March 5, 2015

P125, 000.00

March 10, 2015

P125, 000.00

March 15, 2015

P125, 000.00

Total

P500, 000.00

We understand further that, the checks were delivered to the JMC through its authorized
Corporate Secretary, Mr. Tobi Ocampo. An acknowledgement receipt was issued in favor of
Mr. Pakyaw as proof of the delivery and acceptance of each checks. Thus, on four different
occasions, a corresponding acknowledgement receipt was issued.
We have attached hereto, for your ready reference, a copy of the four acknowledgement
receipts.
Moreover, we understand that the said donations were made orally. Article 748 of the New
Civil Code explicitly provides that donation of personal property with a value exceeding five
thousand pesos (Php5,000) shall be made in writing, otherwise the donation shall be void.

Locsin Bernardo Martin and ASSOCIATES

Attorneys at Law
084 Legis Building, Sampaloc, Manila 1000
Phone (632) 848-0123
lbmlawyers@gmail.com

Since the donations of Mr. Pakyaw exceeded P5,000.00 and were made orally, said donations
are null and void.
Thus, JMC has no right to retain the money donated by Mr. Pakyaw for there is no legal
ground for the former to keep it, the donation being void.
On view of the foregoing, please consider this letter as a demand upon you to return to
Mr. Pakyaw the full amount of Php500,000.00 within five (5) days from receipt hereof.
We trust that you will fully cooperate with us in order that we can settle this matter in the
most mutually fair and expeditious manner.
Sincerely,
Atty. Kathryn Bernardo