ATTY.

JUAN
LAWYER-NOTARY PUBLIC
Sulu Province

November 26, 2018

THE MANAGER
GATEWAY MOTORS INC.

Dear Sir/ Madam;

MR. Pedro, a resident of Isabela City, and one of my highly-valued client, has
sought my legal assistance relative to the defective Nissan Terra, color Aspen Pearl
White, with Engine No. xxxxxxxxxxx & Chassis No. 111111yyyyyyyy, that he
purchased from your company on September 13, 2018.

Accordingly, the said vehicle first manifested its company-origin-defect on

October 27, 2018 while my client was on official travel in Zamboanga City. He recalled
that he parked the vehicle at the shoulder of the road, switched it off and he went to a
fast-food chain to buy a take-out snack. Upon his return to the vehicle, he was
surprised when the vehicle suddenly refused to start. Despite several attempts, the
vehicle still failed to start. Thus, he was constrained to contact your sales agent and
asked for immediate assistance. Courteous as he was, your agent indorsed my client to
your Service Manager “Ryan” and the latter then guided my client in checking the
possible defect of the vehicle. After a couple of “push and pull” on the brake and other
parts of the car, as directed by Ryan, the vehicle regained its normal ignition power. It
started and my client was able to return to Isabela City without encountering the same
dilemma.

My client thought all along that what happened to his car in Zamboanga City
will not happen again as it is a brand new unit and a top of the line model of Nissan
Philippines. To his dismay, however, the same incident occured on November 23, 2018.
While my client was then ready for office on that day, his vehicle again failed to start.
Its ignition power again went down. By this time, my client felt worried and anxious as
his two-month old vehicle suffered a recurring defect. With the incident, my client
again called your sales agent and informed him of the condition of his car. This time,
your agent indorsed my client to your Davao City Branch and facilitated a conversation
with your representative in the said branch. Your Cagayan de Oro Branch assured that
it will extend assitance for the immediate repair of my client’s vehicle.

Surprisingly, however, your Davao City Branch demanded from my client the
payment of P12,000.00, without explaining to him the break down of expenses. My
client was wondering why he was required to pay such amount when in fact his vehicle
is still under warranty, insured and the defect is obviously a “company defect”.

The apparent “company defect” on my client’s car caused so much hassle to him
and to his family, not to mention the additional travelling expenses that they have to
incur in going to their respective offices. My client is a Site Engineer of the DPWH while
his wife is a Dentist of the Department of Education, who every now and then are
required to render work on field using their vehicle. Also, my client is living almost 20
kilometers away from the city proper, hence the necessity of having their own vehicle.

In this connection, may we demand for the immediate repair of my client’s

vehicle, within 15 days from receipt of this letter, without passing to him the burden of
the repair expenses. We humbly believe that my client should not incur any amount for
the repair as the vehicle is still under warranty, insured and its defect is apparently one
that already existed even prior its delivery to my client.

Your company made a warranty to my client that the unit you delivered to him
was of good condition and no hidden issues. With this, we are constrained to invoke
and demand this warranty.

My client is very much willing to settle the matter amicably. If, however, your
good company failed to act on the matter within the given period, we will be
constrained to avail the remedies provided under Republic Act 10642 or the Philippine
Lemon Law and other applicable laws of our country.

We shall be happy to hear from you the soonest.

Very truly yours,

ATTY. JUAN