Overview:

Eleazar Catipay – owner of land who died last june 17, 2019
Smiley catipay – daughter of eleazar and cherlie, who works abroad
Daniel Catipay – brother of Eleazar, lessee of land.
Cherlie Catipay – wife of Eleazar Catipay. She left her husband and
daughter more than a year ago; now that husband is dead, she
wants to claim the land occupied by Daniel Catipay.

Smiley and Daniel came to the office because they want to reply to
the letter sent by Cherlie demanding Daniel to vacate the premises.

DRAFT REPLY:
July 31, 2019

CHERLIE UY CATIPAY

ATTY. ANNA CABANLAS-CAROZ

R.L. SALCEDO CAROZ AND PARTINERS
Ground Floor, KRYZL Building
12th Street, Nazareth
Cagayan de Oro City

Dear Mrs. Cherlie Catipay,

Last July 30, 2019, my client, Mr. Daniel D. Catipay, Sr., sought
my legal advice regarding the letter you sent him demanding him to
vacate the premises he is occupying and to surrender certain personal
properties.

First, your demand for him to vacate the premises do not have
legs to stand on because Mr. Daniel Catipay Sr., has the right to the
physical possession of the property by virtue of the Lease Agreement
executed by and between him, as lessee and Ms. Smiley Uy Catipay,
as lessor. Such agreement is registered under the notarial book of
Atty. Maria Leonita Go (Doc. No. 427, Page No. 86, Book No. 29,
Series of 2019), and is attached herewith.

Second, before you demand the turnover of the personal

properties you enumerated, may I suggest that you verify the
ownership thereof.

Thank you.

Yours Truly,