ATTY. RANDY SACATROPES VILLALUZ, MBA, Ph.D.

R S VILLALUZ LAW OFFICE

Block 7 Lot 2 Satellite Homes 2, San Jose, City of Dasmarinas, Cavite 4114
Mobile Contact Number : (0932) 8456337

THE LAW FIRM OF VILLALUZ GALAPON CADABUNA & ASSOCIATES

Unit 215 2nd Flr. Heritage Bldg., National Highway, Malvar, Santiago City, Isabela 3311
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July 6, 2018

MR. DICKIE BUFFORD ROBBINS

WILLOWTREE DEVELOPMENT CORPORATION
Brent School Baguio, Yangco St., Baguio City

Dear Mr. Robbins:

This is to acknowledge receipt of a letter dated June 28, 2018 from one JOAQUIN R.
BUENAFLOR, Vice President and Treasurer (Mr. Buenaflor for brevity) in response to
our letter dated June 21, 2018. We cannot identify his capacity because the letter was
addressed to you.

Her response does not express regret and we find the offer unacceptable. He stated
that, “This is not in consideration of the amount but a gesture of our unwavering
commitment to be there for our residents.” It was even said to be “unfortunate”, no more,
no less.

We are disappointed because at first it was her understanding that Willowtree will not
be charged anything. But it seems that in your final decision 50% will be charged to us.

The repair stated in our letter refers to a water line leak from the water heater to the
master's toilet and bath. The leaking waterline is imbedded in a concrete wall and
chipping the said wall in order to repair the pipe may compromise the strength of the
wall. Mr. Buenaflor's reply shows that he misunderstood the reference as the damage
to the wall instead of the damage on the water pipe. The water line that leaked from the
water heater to the master's toilet and bath was original. She has not tampered or made
any repair with the existing pipe or wall since the time that they purchased the brand
new unit.

Another statement of Mr. Buenaflor is also misleading. My client was the one who found-
out about the leak when she visited the unit for a vacation. It is wrong for Mr. Buenaflor
to say that, “it was detected and was immediately shut-down”. Had my client not made
the visit, the damage might have been worse.

Also in 2015 and as per information from my client, the unit was only physically turned
over to her upon their purchase. She accepted it based on what was visible within the
unit. There was no way during the turn over for her to determine the high quality or
substandard quality of the plumbing installation or the other systems that are concealed
within the wall. As a recall during the turn-over of the unit there were no plumbing,
sanitary, or electrical specifications which were given.

Water lines from a water heater to the bathroom fixtures are either made of copper pipes
or PPR (Polypropylene) pipes. Based on industry standards and gathered information
on plumbing lifespan, good quality water lines under constant pressure are designed to
last for over fifty (50) years, while drain lines made from cast iron or PVC should last
around seventy-five (75) to a hundred (100) years. Copper pipes, which are also used
for hot water lines last for seventy-five (75) years. This is on the assumption that they

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were connected and installed properly. However, Mr. Buenaflor stated that there is no
more warranty after the lapse of five (5) years. May we ask for a copy of any document
stating about the supposed warranty?

As stated in our letter, although Willowtree is a new developer, with no track record, my
client trusted you on the quality of your building because of its connection with reputable
corporations comprising of the Brent School and the Episcopalian Church of the
Philippines.

By way of compromise, we urge you to immediately proceed with the necessary repair
and that my client will only agree to pay the other fifty percent (50%) upon completion
of the repair and with the condition that you provide her the complete set of documents
and tests that should have been part of the turn-over but were not, such as:

1. As-built architectural, structural, engineering, mechanical, electrical, and

plumbing plans of the unit;

2. Original specification of all material used that are not visible by physical
inspection;

3. Copy of Occupancy permit as proof that units were leased out after
issuance of said permit;

4. List of contractors involved in the construction of the building;

5. Operating manual on the maintenance and care of our unit;

6. Perform hydrostatic pressure tests and leak tests, which were not
performed during turn over; and

7. Electrical inspection and testing, such as insulation resistance testing,

polarity testing, short circuit testing etc., in the presence of our appointed
electrical engineer.

According to my client these are standard turn-over documents which you have not
provided them during the turn-over.

We hope that you understand our position on this matter and immediately undertake the
necessary repair as prolonging the same might affect the strength and integrity of the
unit. And we reiterate that failure on your part to comply would give us no other recourse
but to resort to the filing of cases warranted by the circumstances, including whatever
inconveniences it had brought her.

Thank you.

Sincerely,

(Signed)
ATTY. RANDY S. VILLALUZ, MBA, PhD.

Copy furnished:

MS. SYLVIA BASCON OLIVEROS

S. BASCON HOLDINGS, INC.
#2345 Taft Ave., Pasay City