Date: ________________

The Brgy. Captain / BARC Chairman

Brgy. Captain / BARC Chairperson: With regard to the letter-complaint filed by the Heirs of Yada-yada (the Complainants), may I respectfully submit this letter and the statements contained herein as my answer, to wit: 1. That the property subject of the complaint is identified as Lot 1234, Psd-12345 situated at Brgy. Tyler, Daet, Camarines Norte containing an area of one thousand (1,000) square meters, more or less, and covered by Transfer Certificate of Title No. T-123456; 2. That I, the herein respondent and undersigned ALICE DEE YAN, represented by my mother HALLEY KUH JOHN by virtue of a General Power of Attorney herein attached, am now the owner of said property as evidenced by its certificate of title and the corresponding tax declaration, having acquired the same from its previous owner XXXXXXXXX; 3. That the complainants filed the complaint based on their concern that the adjacent properties which they purportedly own would be affected by the illegal conversion alleged being done in my property; 4. That however, except for A yada-yada and B yada yada under the assumption that they are the same persons as AA yada-yada and BB yada yada, the tax declaration records of the Office of the Provincial Assessor would prove that the complainants are not even the declared owners of the adjacent properties of the land in question, and hence, failing to prove their interests, have no legal standing to file the complaint. (Attached hereto are the original copies of the Tax Declaration of the properties adjacent to the land owned by the Respondent allegedly owned by the Complainants, issued by the Office of the Provincial Assessor); 5. That assuming but not admitting that the Complainants are the real owners and parties-in-interest in this case, they however have failed to adduce any evidence of any injury or damages caused by the alleged illegal conversion in my property; 6. That on the other hand but still under the same assumption, an ocular inspection of the adjacent properties allegedly owned by the complainants would undoubtedly prove that they are the ones committing the consummated crime of illegal conversion on their properties as they have already constructed several concrete residential buildings thereon while as per the tax declarations, the same are still declared irrigated ricelands by actual use, in clear violation of the existing agrarian laws.

7. That with respect to the unfounded allegations hurled by the complainants against the herein undersigned regarding the illegal conversion of my property, the same are mere accusations only and have no basis in law for the following reasons: a. That there is no showing of intent to avoid the application of the existing agrarian laws as even before the filing of the complaint by the herein complainants, I have already initiated before the concerned government agencies my application for the conversion and/or reclassification of the property; b. That there is no tenant in the property to be affected or displaced in my application for conversion/reclassification; and lastly, c. That illegal conversion cannot be said to have been committed because long before my acquisition of the property, the same has already became idle, unproductive, and not suitable for farming or agrarian use anymore. Such fact is supported by the certification coming from the Barangay Captain of Brgy. Tyler, Daet, Camarines Norte, a copy of which is hereto attached; Wherefore, for and in consideration of the foregoing premises, it is most respectfully prayed that the complaint of illegal conversion filed against the herein undersigned by the above-named complainants before the Barangay Council/Government of Tyler, Daet, Camarines Norte be dismissed in the highest interest of justice and equity.

Respectfully yours,

ALICE DEE YAN Landowner Represented by:

XXXXXXXXXXXXXXXXXXX Attorney-in-Fact Pili, Camarines Sur