June 27, 2016

ATTY. ANTONIO S. SORIANO

Chairman, Board of Directors
Philippine National Red Cross
Mis. Or. CDOC Chapter
Capitol, Compound, Cagayan de Oro City

DEMAND LETTER

Dear ATTY. SORIANO,

On behalf of my client, Angel & Sam Const. & Gen. Mdse., please allow me to make this
formal and FINAL DEMAND upon you in your capacity as the Chairman of the Board of
Directors of the Philippine National Red Cross (PNRC), Misamis Oriental Cagayan de Oro
City Chapter, for the IMMEDIATE RELEASE of the balance of the Retention bond which is
continuously and illegally being withheld by your PNRC chapter despite its legal obligation to
release the same.

My client has confided to me that despite several demands over an unjustifiably long period of
time, a significant balance of the retention bond still has not been released to it by the PNRC.
This is being done despite the fact that my client has already complied with all the requirements
in the check list upon which the release of the bond was conditioned. My client was also
surprised when it was informed that the balance of the retention bond would be released only if
its authorized representative would sign a waiver, release and quitclaim to the effect that it
no longer has any other claims against the PNRC Mis. Oro CDO Chapter.

Regrettably, my client cannot concede to the demand of your PNRC Chapter because it is
known to both parties that my client still has a remaining collectible of Three Hundred Fifty Six
Thousand Six Hundred Sixty Three Pesos and 29/100 (PhP356,663.29). I understand that the
payment of this remaining collectible is still to be discussed by your board. However the
pendency of the payment of such amount cannot be a ground to illegally withhold the retention
bond of my client. Especially that it has already been around two years since you have actually
started occupying the building subject of this bond and all the pre-requisites for its release have
been complied with.
Please urgently consider this FINAL DEMAND and RELEASE to my client the balance of its
retention bond within FIVE (5) days from receipt of this letter, otherwise my client will be
forced to file the necessary CRIMINAL and CIVIL charges against the Philippine National Red
Cross Mis. Or. CDO Chapter and its responsible officers. Considering that the PNRC is a
charitable institution which has a reputation to protect, I am hoping that you would be able to
help in ensuring that this demand will be promptly addressed without need for any further
legal action. Thank you very much.

Sincerely,

ATTY. ALEJANDRO JOSE C. PALLUGNA

Counsel for Angel & Sam Const. & Gen. Mdse.