Banzuela Banzuela Banzuela & Associates Law Offices
Banzuela Banzuela Banzuela & Associates Law Offices
Banzuela Banzuela Banzuela & Associates Law Offices
Of Counsel:
NAPOLEON C. BANZUELA, JR.
12 July 2021
LEONIDA MORADA
#786 Atis St., Teachers Village
Lupang Pari, Brgy, San Miguel
1600 Pasig City
Our clients, Sps. AJay M. Francisco and Wenniefreda G. Francisco have referred to our firm for
immediate legal action as regards a house and lot consisting of 30 square meters, more or less
situated at #786 Teachers Village, Lupang Pari, Brgy. San Miguel, Pasig City which you have
sold to them in the amount of P200,000.00 as evidenced by Kasunduan sa Pagbenta ng Bahay at
Lote dated 06 November 2018.
According to our clients, prior to the aforesaid sale, the same property had been subject of a real
estate mortgage denominated as “Kasunduan ng Pagsanglang Bahay” dated 06 August 2014
which loan in the amount of P65,000,00 you have failed to settle for which you have just decided
to sell the same to our clients.
However, recently, our clients discovered that you are not the real owner of the subject property
at the time of the aforesaid sale but your daughter, LEAH MORADA SADSAD by virtue of the
Deed of Absolute Sale entered into by the former owner, FLORENTINO B. ROSARIO and your
aforesaid daughter dated 21 April 2016. Worse, even during the time that you have mortgaged
the property it was still owned by FLORENTINO B. ROSARIO.
In this regard, we demand from you to immediately settle with our clients as to how they will
transfer the property in their name from your daughter, LEAH
MORADA SADSAD, the real owner within ten (10) days from receipt heroef otherwise much to
our regret we shall institute the appropriate legal action including but not limited to pressing
criminal charges for estafa under Art. 315 of the Revised Penal Code against you and hold you
further liable for damages, attorney’s fees and costs of suit.
Please be guided accordingly.