FORMAL COMPLAINT & LEGAL DEMAND PACKAGE

DATE: November 3, 2026

VIA REGISTERED MAIL WITH RETURN RECEIPT AND EMAIL

TO:

ANCHOR LAND HOLDINGS, INC.

Customer Care and Management Division

11th Floor, L.V. Locsin Building,

Ayala Avenue corner Makati Avenue, Makati City, Philippines

Email: [email protected] / [email protected]

ATTENTION: Customer Service Management and Legal Affairs Department

SUBJECT: FORMAL NOTICE OF GRIEVANCE, INVOCATION OF RIGHTS UNDER SECTION 23 OF PRESIDENTIAL DECREE NO. 957, AND FINAL DEMAND FOR REMEDIES REGARDING DELAYED TURNOVER (COPETON BAYSUITES – STUDIO UNIT)

1. FORMAL NOTICE OF GRIEVANCE

Dear Executive Management and Customer Relations Team,

This document serves as a formal Notice of Grievance and Legal Demand issued to Anchor Land Holdings, Inc. (“Developer”) by the undersigned buyer regarding the purchase of a Studio Unit located within the Copeton Baysuites development in the Manila Bay area, Parañaque City, Metro Manila.

As of the date of this letter, the subject unit is over twelve (12) months past its contractually and statutorily committed turnover deadline. Despite full compliance by the buyer with all financial and administrative obligations under the Contract to Sell (CTS) and Reservation Agreement, the Developer has failed to complete and turn over the unit. Furthermore, the Developer has failed to issue any official, written justification detailing legitimate delays or providing an authenticated, legally binding timeline for completion.

This submission establishes formal legal notice prior to initiating regulatory proceedings before the Department of Human Settlements and Urban Development (DHSUD) and filing an administrative complaint with the Human Settlements Adjudication Commission (HSAC).

2. CHRONOLOGICAL ACCOUNT OF EVENTS & DETAILED INCIDENT MATRIX

Date / Timeline	Event Description & Stage	Supporting Reference / Document	Communication & Representation Details
Initial Purchase Date	Execution of Reservation Agreement and payment of reservation fee for Copeton Baysuites Studio Unit.	Reservation Agreement / Official Receipts	Sales agents represented project target completion and initial turnover timeline.
CTS Execution	Signing of the Contract to Sell (CTS) and adherence to the equity payment schedule.	Contract to Sell (CTS) No. [Insert CTS No.]	Fixed turnover date stipulated per developer’s License to Sell and CTS provisions.
Full Equity Completion	Buyer completed equity amortizations as agreed.	Official Receipts / Statement of Account	All buyer obligations were kept up-to-date and in good standing.
Stipulated Turnover Date	Promised completion and unit handover date passed without unit delivery.	CTS Turnover Clause / Marketing Collateral	No formal notice of extension or Certificate of Occupancy was presented.
6 Months Post-Deadline	Informal inquiries made to sales agent and customer support regarding delay.	Verbal & Messaging Records	Verbal reassurances were given without official written commitments.
12+ Months Delay (Current)	Turnover remains overdue by over 12 months with zero official written justification.	Dated Site Inspection / SOA	Customer care and management teams have provided unkept promises and runarounds.

Summary of Failure of Communication and Due Process:

1. Unkept Commitments: Verbal commitments from sales agents and generic customer service responses continuously shifted projected delivery dates without factual basis or regulatory backing.
2. Lack of Transparency: No written explanations citing valid, verified force majeure events under Article 1174 of the Civil Code have been formally served.
3. Misleading Sales Conduct: Representations made during the pre-selling phase regarding construction speed and delivery schedules have not been met, constituting unfair real estate practices under DHSUD guidelines.

3. STATUTORY RIGHTS AND LEGAL FRAMEWORK

The buyer’s grievances are grounded in Philippine real estate protection laws and contract law:

A. Presidential Decree No. 957 (Subdivision and Condominium Buyers’ Protective Decree)

• Section 20 (Time of Completion): Requires every owner or developer to construct and complete the project according to approved plans and specifications within one (1) year from the date of issuance of the license or the period fixed by the regulator.
• Section 23 (Non-Forfeiture of Payments):

“No installment payment made by a buyer in a subdivision or condominium project for the lot or unit he contracted to buy shall be forfeited in favor of the owner or developer when the buyer, after due notice to the owner or developer, desists from further payment due to the failure of the owner or developer to develop the project according to the approved plans and within the time limit for complying with the same. Such buyer may, at his option, be reimbursed the total amount paid including amortization interests but excluding delinquency interests, with interest thereon at the legal rate.”

B. Civil Code of the Philippines

• Article 1169 (Mora Solvendi): Establishes that those obliged to deliver or do something incur delay from the time the obligee judicially or extrajudicially demands fulfillment of their obligation.
• Article 1191 (Right of Rescission): The power to rescind reciprocal obligations is implied in cases where one of the obligors does not comply with what is incumbent upon them, giving the injured party the choice between demanding fulfillment or rescission with damages.

C. Regulatory Jurisprudence & Interest Rates

Under established Supreme Court doctrines (e.g., Spouses Ronquillo v. Fil-Estate Properties, Inc.) and BSP Circular No. 799, a developer in breach of turnover timelines must refund 100% of all payments made with legal interest at six percent (6%) per annum computed from the date of formal extrajudicial demand.

4. FORMAL DEMANDS

Anchor Land Holdings, Inc. is hereby formally requested to choose and execute one of the following two remedies within fifteen (15) calendar days upon receipt of this letter:

OPTION A: SPECIFIC PERFORMANCE AND BINDING TURNOVER (IF PROCEEDING WITH PURCHASE)

1. Executing a Binding Addendum: Issue a notarized Addendum to the Contract to Sell specifying a firm, final turnover date for the Copeton Baysuites Studio Unit.
2. Official Explanation & Certifications: Provide certified true copies of the project’s DHSUD License to Sell, Certificate of Registration, and Building Occupancy Permit issued by the local government unit.
3. Liquidated Damages: Credit contractual liquidated damages or delay compensation equal to standard legal rates or contractual penalties against any remaining balance or move-in fees due from the buyer.

OPTION B: FULL REFUND AND CONTRACT RESCISSION UNDER SECTION 23 (PD 957)

1. Full Reimbursement: Remit a full refund of one hundred percent (100%) of all payments made (including reservation fees, equity payments, and amortizations).
2. Legal Interest: Include statutory legal interest at the rate of six percent (6%) per annum, calculated from the date of receipt of this demand letter until full payment.
3. Waiver of Penalties: Confirm in writing that no delinquency fees, administrative charges, or forfeiture penalties will be assessed against the buyer.

5. ESCALATION PLAN & REGULATORY FILING NOTICE

If Anchor Land Holdings, Inc. fails to respond, disputes this demand, or fails to satisfy either Option A or Option B within fifteen (15) calendar days, the buyer will proceed with the following enforcement measures:

1. DHSUD Regional Office Filing: File a Request for Regulatory Verification and Administrative Intervention with the DHSUD Regional Office having jurisdiction over Parañaque City to verify whether any extension was authorized.
2. HSAC Adjudication: File a Verified Complaint-Affidavit before the Human Settlements Adjudication Commission (HSAC) claiming:
   • Rescission of Contract and 100% Refund with Interest under Sec. 23, P.D. 957;
   • Moral and Exemplary Damages for bad faith and unkept representations;
   • Attorney’s Fees and Costs of Litigation;
   • Administrative Fines under Section 38 of P.D. 957.
3. Public and Banking Notices: Send notification to financing banks to withhold amortization disbursements until a Certificate of Occupancy and Turnover Notice are issued.

6. VERIFICATION AND DRAFTING ACKNOWLEDGMENT

RESPECTFULLY SUBMITTED.

[BUYER’S FULL LEGAL NAME]

Owner / Complainant – Copeton Baysuites Studio Unit

Contact Number: [Insert Phone Number]

Email Address: [Insert Email Address]

Mailing Address: [Insert Mailing Address]

Copy Furnished via Certified Mail:

• Department of Human Settlements and Urban Development (DHSUD)

Central Office / Regional Office (NCR/Region IV-A)

• Human Settlements Adjudication Commission (HSAC)

Legal Affairs and Adjudication Bureau