⬛ Personal home addresses and card numbers REDACTED in this version | CONFIDENTIAL — FOR BSP / SEC REGULATORS AND LEGAL COUNSEL ONLY | Case ID 19305061
I.S. No.: ___________________
For: Unjust Vexation (Art. 287, Rev. Penal Code); Violation of R.A. 10870; Violation of R.A. 10173; Violation of R.A. 11765
RAFAEL ALFONSO TAN POSADAS,
Complainant,
-versus-
SECURITY BANK CORPORATION;
RGS RECOVERY MANAGEMENT &
COLLECTIONS SERVICES, INC.;
S.P. MADRID & ASSOCIATES;
EDERLYN VILLANUEVA,
in her personal capacity as Team Leader,
RGS Recovery Management & Collections
Services, Inc.;
BENMOREEN NAZARENO,
in her personal capacity as Legal Officer,
S.P. Madrid & Associates; and
JOHN/JANE DOES 1–10,
Respondents.
|
|
Complaint-Affidavit
I, RAFAEL ALFONSO TAN POSADAS, of legal age, Filipino citizen, currently residing at 1240 E. Plaza Blvd. Ste. 604 PMB# 454, National City, California 91950, United States of America, with Philippine address at ████████████████████████████, Paombong, Bulacan 3001, after having been duly sworn to an oath in accordance with law, do hereby depose and state that:
I. PRELIMINARY STATEMENT
1.I am the holder of Security Bank Corporation credit card accounts bearing the last four (4) digits ████ (Platinum) and ████ (Next). I have maintained a continuous payment history with Security Bank for approximately five (5) years.
2.I am presently based in the United States and am unable to physically appear before any Philippine office. I am executing this Complaint-Affidavit before a notary public in the State of California, and it is being apostilled pursuant to the Hague Convention of 5 October 1961, to which the Philippines acceded in 2019, rendering this document fully valid and admissible in Philippine proceedings without further authentication.
3.I am filing this complaint against: (a) Security Bank Corporation, a corporation duly organized under Philippine law with principal offices at Security Bank Centre, 6776 Ayala Avenue, Makati City; (b) RGS Recovery Management & Collections Services, Inc. (hereinafter "RGS Recovery"), a collection agency operating at 3F/4F Anonas LRT City Center, 968 Aurora Blvd., Proj. 4, Quezon City — the place of business being within the jurisdiction of this Honorable Office; (c) S.P. Madrid & Associates (hereinafter "S.P. Madrid"), a collections law firm with offices at 17th Floor, Chatham House Condominium, V.A. Rufino cor. Valero, Brgy. Bel-Air, 1226 City of Makati, NCR; Tel: (02) 8538-6403; Mobile: 0919-059-9967; Email: sblegal@spmadridlaw.com; (d) Ederlyn Villanueva, Team Leader of RGS Recovery, in her personal capacity; (e) Benmoreen Nazareno, Legal Officer of S.P. Madrid & Associates, in her personal capacity; and (f) John/Jane Does 1-10, whose identities have not yet been fully established.
4.The acts complained of constitute: (a) Unjust Vexation under Article 287 of the Revised Penal Code; (b) Violation of Republic Act No. 10870 (Philippine Credit Card Industry Regulation Law), particularly Sections 19 and 21 thereof; (c) Violation of Republic Act No. 10173 (Data Privacy Act of 2012), particularly Sections 25 and 31 thereof; and (d) Violation of Republic Act No. 11765 (Financial Products and Services Consumer Protection Act) and its implementing regulations, including BSP Circular No. 1048 and SEC Memorandum Circular No. 18.
II. PARTIES AND JURISDICTION
5.RGS Recovery Management & Collections Services, Inc. maintains offices at 3F/4F Anonas LRT City Center, 968 Aurora Blvd., Proj. 4, Quezon City. The acts complained of — including the dispatch of 13 documented harassing collection emails and the deployment of an unidentified collection agent — originated from and were authorized by personnel at this Quezon City address. Jurisdiction of this Honorable Office is accordingly proper.
6.Security Bank's engagement of RGS Recovery as its collection agent and its direction of collection activities against the complainant make Security Bank equally amenable to the jurisdiction of this Honorable Office for all acts carried out by its agents within Quezon City.
III. STATEMENT OF FACTS
A. Background — Dispute Filed and Acknowledged
7.On March 6–7, 2026, I formally filed a written dispute and Final Notice directed to Security Bank Corporation and RGS Recovery Management & Collections Services, Inc., documenting ongoing violations of my rights as a credit card debtor under Philippine law and demanding the immediate cessation of unlawful collection activity.
8.On March 25, 2026, Security Bank Corporation formally acknowledged my open dispute via email, assigning Case ID 19305061, and confirming that their team was actively processing the matter. This acknowledgment was received at 11:55 PM Pacific Standard Time on March 25, 2026.
9.Despite this formal acknowledgment, collection activity against me — on the same disputed accounts covered by Case ID 19305061 — was never suspended and continued unabated through and including April 4, 2026, the date of the most recent documented collection email. This willful continuation of collection activity against a debtor with an open, acknowledged dispute constitutes the core of the illegal conduct complained of herein.
B. RGS Recovery — 13 Harassing Collection Emails (March 3–23, 2026)
10.Between March 3 and March 23, 2026, RGS Recovery sent me a total of thirteen (13) collection emails through the address evillanueva@rgsrecovery.net, and subsequently through the personal account of Team Leader Ederlyn Villanueva at evillanueva@rgs.com.ph. Each automated email was signed only by an unidentified "Legal Officer," with no individual name disclosed, no IBP Roll Number, and no physical office address — in direct violation of SEC MC No. 18.
11.The automated collection emails each demanded payment of PHP 35,028.27 and each stated "Pay by 5 PM today" — a demand that had already expired at the time of receipt in the United States given the time zone differential. This is a deceptive misrepresentation under RA 10870, Section 19 and RA 11765.
12.Email #11 in Exhibit A, dated March 12, 2026, constitutes a personal reply from Ederlyn Villanueva acknowledging receipt of my Final Notice — yet automated demands continued on March 14 and March 23, establishing willful harassment after actual knowledge of my formal legal notice.
13.Email #6 in Exhibit A was transmitted at 11:20 PM Pacific Standard Time on March 6, 2026, which falls within the prohibited contact hours under SEC MC No. 18 (after 10:00 PM). This constitutes an additional and independent violation.
C. RGS Recovery — Unauthorized Viber Contact (March 7, 2026)
14.On March 7, 2026, at 5:49 PM Philippine Time, RGS Recovery contacted me through the Viber messaging platform using an account registered under the name "RGS SECURITY BANK." The contact included both an unsolicited text message and a missed call — through a platform to which I never consented.
15.I have never, at any point, consented to the use of Viber or any third-party messaging platform for communications related to my Security Bank credit card accounts. The use of the account name "RGS SECURITY BANK" constitutes deceptive misrepresentation designed to create the false impression of official Security Bank contact, in violation of RA 10870, Section 19. The unauthorized processing of my personal contact information through a non-consented platform violates RA 10173, Sections 25 and 31. This incident is documented in Exhibit C.
D. First Unidentified Collector Visit (On or Before March 16, 2026)
16.Prior to March 16, 2026, an unidentified individual acting as a collection agent arrived at my Philippine residence on a motorcycle. I was not present, as I reside in the United States. This collector did not remove his helmet — deliberately concealing his face. He identified himself only as "Taga-Security Bank," asked for me by name, was informed I was in the United States, and immediately left without providing any identification, employee ID, badge, letter of authority, or any official document.
17.The collector's disclosure of my identity as the debtor on a Security Bank credit card account to my in-laws — third parties with no legal standing in the debt matter — constitutes unauthorized disclosure of confidential financial information in violation of RA 10173, Sections 25 and 31, and the Bank Secrecy Law (RA 1405). A Barangay Blotter was filed on March 16, 2026 at Barangay Sto. Rosario, Paombong, Bulacan, as documented in Exhibit B.
E. Security Bank's Failure to Suspend Collection — The 25-Minute Window (March 25, 2026)
18.On March 25, 2026, at 11:30 PM Pacific Standard Time, S.P. Madrid & Associates, through Benmoreen Nazareno, transmitted a collection demand email pressuring me to make immediate payment of PHP 53,685.29 on the very accounts subject to my open dispute.
19.Twenty-five (25) minutes later, at 11:55 PM Pacific Standard Time on the same evening, Security Bank Corporation transmitted its acknowledgment email for Case ID 19305061, confirming that my dispute was open and being processed.
20.This 25-minute window establishes that Security Bank had actual and constructive knowledge of my open dispute at the precise moment its authorized collection agent was actively pressuring me for payment on the same disputed accounts. Security Bank's failure to instruct S.P. Madrid & Associates to suspend collection activity constitutes a direct violation of its obligations under RA 11765 and demonstrates bad faith conduct under BSP Circular No. 1048. This is documented in Exhibit D.
F. S.P. Madrid & Associates — 18 Harassing Collection Emails (March 25–April 4, 2026)
21.Between March 25 and April 4, 2026, S.P. Madrid & Associates sent me a total of eighteen (18) collection emails through the shared address sblegal@spmadridlaw.com, averaging nearly two (2) emails per day. None of the named officers disclosed any IBP Roll Number in any communication — a clear violation of SEC MC No. 18.
22.Email #1 of the S.P. Madrid log (Exhibit E) was received at 10:30 PM Pacific Standard Time on March 25, 2026 — within the prohibited contact hours under SEC MC No. 18 (after 10:00 PM local time of the debtor). This constitutes an independent violation.
23.S.P. Madrid officers "Joanna" (Email #8, March 28, 2026) and "RJRAZON" (Email #14, March 31, 2026) identified themselves only by incomplete names — one by first name only, the other by initials only — with no surname and no IBP Roll Number disclosed, in violation of SEC MC No. 18.
24.Email #10 (March 30, 2026), from Lenie Aton, constitutes a direct reply to my Addendum of March 26, 2026 — acknowledging receipt of my formal legal notice and continuing to demand payment nonetheless, establishing willful continuation of collection activity after actual knowledge of the dispute.
25.Email #12 (March 30, 2026) from Rona Mae Gubalane claimed that "Atty. Madrid is currently here in our office" and set a 3:00 PM payment deadline with a threat to endorse to the Legal Department — constituting coercive threats of legal action during an open acknowledged dispute.
G. Dual-Agency Violation — RA 10870, Section 21
26.Section 21 of RA 10870 strictly prohibits a credit card issuer from engaging more than one (1) collection agency at a time on a single debtor's account. Security Bank Corporation violated this prohibition by simultaneously engaging both RGS Recovery Management & Collections Services, Inc. and S.P. Madrid & Associates as collection agents on my account.
27.The overlap is conclusively established by the documentary record: Email #13 in the RGS Recovery log (Exhibit A) was sent on March 23, 2026 — while S.P. Madrid's engagement had already commenced, with S.P. Madrid's first contact occurring on March 25–26, 2026. At minimum, a period from March 23–25, 2026 existed during which two collection agencies were simultaneously engaged on my account in direct violation of RA 10870, Section 21.
H. Second Unidentified Collector Visit (March 30, 2026)
28.On March 30, 2026 — five (5) days after Security Bank formally acknowledged my dispute under Case ID 19305061 — a second unidentified individual appeared at my Philippine residence. This visitor identified himself as being from Security Bank Corporation and discussed my unpaid credit card account with my in-laws. He provided no name, badge, employee ID, or letter of authority.
29.This visit was made on a disputed account during an active acknowledged dispute period, in violation of RA 11765 and BSP Circular 1048. The unauthorized disclosure of my financial information to my in-laws again violates RA 10173 and RA 1405. If this visitor was a third-party collection agent, his engagement would constitute a third simultaneous collection agency — a further aggravated violation of RA 10870, Section 21. This incident is documented in Exhibit F.
IV. CAUSES OF ACTION
First Cause of Action: Unjust Vexation — Article 287, Revised Penal Code
30.The acts of all Respondents, individually and collectively, constitute Unjust Vexation under Article 287 of the Revised Penal Code. The 13 automated harassing emails from RGS Recovery, the 18 automated harassing emails from S.P. Madrid & Associates (totaling 31 collection communications in approximately 33 days), two unauthorized home visits, Viber contact through a deceptively named account, late-night contact violating prohibited hours, and willful continuation of all of the foregoing after actual knowledge of the open formal dispute — taken together and each independently — caused the complainant annoyance, irritation, vexation, torment, distress, and indignation without legal justification.
31.The vexation is particularly aggravated by: (a) deliberate concealment of the first collector's identity by keeping his helmet on; (b) the deceptive "RGS SECURITY BANK" Viber account name; (c) continued automated demands after Ederlyn Villanueva personally acknowledged the Final Notice; (d) continued demands after Lenie Aton personally replied to the Addendum; and (e) the second home visit made five days after Security Bank's own systems acknowledged the dispute under Case ID 19305061.
Second Cause of Action: Violation of RA 10870
32.Respondents violated RA 10870, particularly Sections 19 and 21, through: (a) use of deceptive and misleading collection practices, including the already-expired "5 PM today" deadline, the deceptive "RGS SECURITY BANK" Viber account name, and coercive threats during an open dispute; (b) failure of all collection personnel to identify themselves fully, including name, IBP Roll Number, and physical office address; and (c) simultaneous engagement of two collection agencies on the same account, in direct violation of the one-agency rule of Section 21.
Third Cause of Action: Violation of RA 10173
33.Respondents violated RA 10173, Sections 25 and 31, through: (a) unauthorized disclosure of the complainant's confidential financial information to third parties (in-laws) during two unauthorized home visits; (b) unauthorized processing of the complainant's personal contact data through the Viber platform without consent; and (c) use of the complainant's personal data beyond the scope of consented use at account opening.
Fourth Cause of Action: Violation of RA 11765
34.Security Bank Corporation violated RA 11765 and BSP Circular No. 1048 by: (a) failing to instruct its collection agents to suspend collection activity upon opening of a formal dispute under Case ID 19305061; (b) continuing to authorize and direct collection activity — including two physical home visits — after its own systems formally acknowledged the dispute; and (c) engaging collection agents who employed deceptive, coercive, and harassing practices in violation of the consumer protection standards established by RA 11765.
V. PRAYER
WHEREFORE, premises considered, complainant respectfully prays that:
- A preliminary investigation be conducted forthwith against all Respondents for the offenses charged herein;
- An Information be filed against Security Bank Corporation, RGS Recovery Management & Collections Services, Inc., S.P. Madrid & Associates, Ederlyn Villanueva, Benmoreen Nazareno, and John/Jane Does 1-10 for Unjust Vexation under Article 287 of the Revised Penal Code and for all applicable violations of RA 10870, RA 10173, and RA 11765;
- Appropriate criminal charges be referred to the Securities and Exchange Commission (SEC) and the Bangko Sentral ng Pilipinas (BSP) for concurrent regulatory action;
- The identities of the two (2) unidentified collectors who visited complainant's Philippine residence on or before March 16, 2026 and on March 30, 2026 be compelled to be disclosed by Security Bank Corporation and its agents; and
- Such other and further relief as may be just and equitable under the premises be granted.
IN WITNESS WHEREOF, I have hereunto affixed my signature this ______ day of ____________ 2026 in National City, California, United States of America.
RAFAEL ALFONSO TAN POSADAS
Affiant / Complainant
1240 E. Plaza Blvd. Ste. 604 PMB# 454
National City, California 91950, USA
ralphposadas29@gmail.com
JURAT
SUBSCRIBED AND SWORN to before me this ______ day of _________________, 2026, in _______________________, California, personally appeared the affiant RAFAEL ALFONSO TAN POSADAS, who is personally known to me or who proved his identity on the basis of satisfactory evidence to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person executed the instrument.
I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.
WITNESS my hand and official seal.
NOTARY PUBLIC
Signature:
Name:
Commission No.:
Expiry Date:
County of:
State of: California
[NOTARY SEAL]
APOSTILLE
California Secretary of State
April 8, 2026
(Apostille to be affixed here by the California Secretary of State pursuant to the Hague Convention of October 5, 1961)
APOSTILLE NOTE: This document was notarized before a California notary public and apostilled by the California Secretary of State pursuant to the Hague Convention Abolishing the Requirement of Legalisation for Foreign Public Documents (October 5, 1961). The Philippines acceded to the Convention on May 14, 2019 (effective June 14, 2019). This apostille renders the document fully valid in the Philippines without further authentication by the Department of Foreign Affairs or any Philippine consulate.
DOCUMENTARY EXHIBITS ATTACHED
The following documentary exhibits are attached to and made integral parts of this Complaint-Affidavit:
- Exhibit A — RGS Recovery Harassment Log (13 documented emails, March 3–23, 2026)
- Exhibit B — Barangay Blotter, Barangay Sto. Rosario, Paombong, Bulacan (filed March 16, 2026)
- Exhibit C — Viber Unauthorized Contact Screenshot (March 7, 2026; RGS SECURITY BANK account)
- Exhibit D — Security Bank Case ID 19305061 Acknowledgment Email (March 25, 2026, 11:55 PM PST)
- Exhibit E — S.P. Madrid & Associates Harassment Log (18 documented emails, March 25–April 4, 2026)
- Exhibit F — Second Unidentified Collector Visit Documentation (March 30, 2026)
- Exhibit G — Ederlyn Villanueva Personal Reply Acknowledging Final Notice (March 12, 2026)
- Exhibit H — RGS Recovery Automated Collection Email Template — Verbatim Sample (Email #13, March 23, 2026)
- Exhibit I — S.P. Madrid & Associates Generic Boilerplate Email — Verbatim Sample (Email #18, April 4, 2026)
All email logs in Exhibits A and E were compiled directly from the Gmail inbox of ralphposadas29@gmail.com. Timestamps are sourced from original authenticated email headers and are unaltered.
Respectfully submitted,
RAFAEL ALFONSO TAN POSADAS
Complainant
April 8, 2026
EXHIBIT G
Ederlyn Villanueva Personal Reply — Acknowledging Final Notice
RGS Recovery Management & Collections Services, Inc.
Thursday, March 12, 2026 at 5:08 AM UTC (9:08 PM PST, March 11, 2026)
Prepared: April 5, 2026 | Reference: Security Bank Case ID 19305061
Violations documented: RA 10870 §§19, 21; SEC MC No. 18; RA 11765; Article 287 Revised Penal Code
Legal significance: This email is Email #11 in Exhibit A. It constitutes Ederlyn Villanueva's personal, direct acknowledgment of receipt of the complainant's Final Notice — establishing that RGS Recovery had actual, personal knowledge of the formal legal dispute as of March 12, 2026. Despite this acknowledgment, RGS Recovery continued automated collection demands on March 14 (Email #12) and March 23 (Email #13), establishing willful harassment after formal notice.
| EMAIL HEADERS |
| From | Ederlyn S. Villanueva, Team Leader <evillanueva@rgs.com.ph> |
| To | Ralph Posadas <ralphposadas29@gmail.com> |
| Date | Thursday, March 12, 2026 at 5:08 AM UTC (9:08 PM PST, March 11, 2026) |
| Subject | Re: FINAL NOTICE: Intent to File Criminal and Administrative Charges for Unfair Debt Collection, Misrepresentation, and Data Privacy Violations |
| Sender Office | 3F/4F Anonas LRT City Center, 968 Aurora Blvd. Proj. 4, Quezon City |
| Sender Mobile | +63 936 059 0363 |
Reply Body (Verbatim)
We acknowledge receipt of your email.
Please be advised that our representative was trying to contact you on your registered contact numbers but to no avail. May we confirm your updated contact number and preferred callback time so we can discuss your concerns on account. Thank you
Ederlyn S. Villanueva
Team Leader
+63 936 059 0363
www.rgs.com.ph
evillanueva@rgsrecovery.com.ph
3F/4F Anonas LRT City Center, 968 Aurora Blvd. Proj. 4, Quezon City
Legal Analysis
1.Acknowledgment Without Substantive Response: Villanueva's reply confirms receipt of the Final Notice but offers no legal response to any documented violations — no commitment to cease collection, no acknowledgment of the dual-agency issue, no IBP Roll Number, no Letter of Authority.
2.Attempt to Shift to Phone: The request for a callback number attempts to move the dispute off the written, documented record and onto an unrecorded verbal channel — depriving the complainant of documentary evidence.
3.Willful Continuation Proven: Despite this personal acknowledgment on March 12, RGS Recovery sent two additional automated collection demands on March 14 (Email #12) and March 23 (Email #13) — proving Villanueva's acknowledgment did not result in any internal instruction to suspend collection.
4.Identity Confirmed: This email independently confirms Villanueva's identity as Team Leader (evillanueva@rgs.com.ph), mobile number (+63 936 059 0363), and the Quezon City office address — all cited in the complaint.
Sub-Attachment G-1: Complainant's Final Notice (March 12, 2026)
The following is the Final Notice to which Villanueva replied, transmitted March 12, 2026 at 11:52 AM PHT, CC'd to the BSP, SEC, and NPC:
| From | Ralph Posadas <ralphposadas29@gmail.com> |
| To | customercare@securitybank.com; sbccollections@securitybank.com.ph; evillanueva@rgsrecovery.net; evillanueva@rgs.com.ph |
| CC | consumeraffairs@bsp.gov.ph; imessagemo@sec.gov.ph; complaints@privacy.gov.ph |
| Date | Thursday, March 12, 2026 at 11:52 AM PHT |
| Subject | FINAL NOTICE: Intent to File Criminal and Administrative Charges for Unfair Debt Collection, Misrepresentation, and Data Privacy Violations |
ATTENTION:
- E. Villanueva, RGS Recovery Management & Collections Services, Inc.
- Victor Lee Meng Teck, President & CEO, Security Bank Corp.
- Anna Christina M. Chinjen, Chief Compliance Officer, Security Bank Corp.
This is a Formal and Final Notice. Despite my "Dispute and Request for Debt Validation" sent on March 7, 2026, at 5:12 PM (PST), RGS Recovery (specifically through the office of E. Villanueva) has intentionally ignored my legal request and escalated its harassment.
I. STATEMENT OF ACCOUNT HISTORY & LOYALTY
I have been a loyal Security Bank cardholder for over five (5) years. Throughout this tenure, I have maintained a strong payment record. This current dispute is an anomaly in a long-term relationship. Instead of professional coordination, Security Bank and its agent, RGS, have chosen a path of predatory harassment, which I will not tolerate.
II. LEGAL JUSTIFICATION FOR NAMING TOP EXECUTIVES
Security Bank has failed to provide the mandatory 7-day written notice required under RA 10870 prior to endorsing my account to a third-party agency. Under the principle of Solidary Liability, the top leadership is directly accountable for the illegal, unauthorized, and tortious acts of their agents.
III. DOCUMENTED HARASSMENT & PRIVACY VIOLATIONS
RGS Recovery sent identical automated demands signed by a generic "Legal Officer" without IBP Roll Number or physical address. Unauthorized Viber contact under "RGS SECURITY BANK" on March 7, 2026. Home intrusion disclosing financial information to in-laws — severe breach of Bank Secrecy and Data Privacy Act.
IV. FINAL FIVE (5) DAY DEMAND
- Full Validation of Debt — certified, itemized Statement of Account (SOA)
- Official Letter of Authority — proof of RGS's authorization from Security Bank
- Identity Disclosure — full name and IBP Roll Number of the "Legal Officer"
- Cease and Desist — immediate termination of all Viber and third-party communications
Failure to comply will result in the immediate filing of a Criminal Complaint for Unjust Vexation with the Office of the City Prosecutor of Quezon City and administrative cases with the BSP, SEC, and NPC.
Sincerely,
RAFAEL ALFONSO POSADAS
ralphposadas29@gmail.com
— END OF EXHIBIT G —
EXHIBIT I
S.P. Madrid & Associates — Generic Boilerplate Collection Email (Verbatim)
Representative Sample: Email #18 · Saturday, April 4, 2026 · 10:07 AM PHT
This same template was sent by Junior Michael Agramon on 8 separate occasions
Source: sblegal@spmadridlaw.com | Reference: Security Bank Case ID 19305061
| EMAIL HEADERS |
| From | SP MADRID & ASSOCIATES <sblegal@spmadridlaw.com> |
| Reply-To | SP MADRID & ASSOCIATES <sblegal@spmadridlaw.com> |
| To | ralphposadas29@gmail.com |
| Date | Saturday, April 4, 2026 at 07:37 +0530 (10:07 AM PHT) |
| Subject | SECURITY BANK CORPORATION Account - Settlement Reminder | SPMB2 BNAZARENO |
Email Body (Verbatim — Reproduced Exactly as Received)
Dear RAFAEL ALFONSO POSADAS,
This is Junior Michael Agramon from SP Madrid and Associates. Please be advised that your overdue account has been officially endorsed to our law firm by Security Bank Corporation.
For any actions or inquiries regarding your Security Bank account, kindly contact us immediately at (02) 8538 6403 / 0919 059 9967, or email us at sblegal@spmadridlaw.com.
Thank you for your prompt attention to this matter.
Regards,
S.P. Madrid & Associates
___________________________________
E-mail: sblegal@spmadridlaw.com
Mobile No.: 0919-059-9967
Landline No.: (02) 85386403
Address: 17th Floor, Chatham House Condominium, V.A. Rufino cor. Valero, Brgy. Bel-Air, 1226 City of Makati, Fourth District, NCR
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Annotated Legal Violations in This Template
[1]NO IBP ROLL NUMBER: Agramon signs by name only with no IBP Roll Number — despite SP Madrid presenting itself as a law firm with "Legal Officers." Violates SEC MC No. 18 mandatory identification requirements.
[2]NO PROFESSIONAL CREDENTIALS: No bar accreditation, no authority to make legal demands disclosed. The law firm letterhead implies legal authority that is entirely unsubstantiated in the email.
[3]SENT 9 DAYS AFTER ADDENDUM: Email #18 (April 4) was sent 9 days after the Addendum was transmitted to SP Madrid on March 26 — and 10 days after Security Bank acknowledged the open dispute under Case ID 19305061.
[4]IDENTICAL TEMPLATE ×8: This exact template appears as Emails #2, #3, #6, #13, #15, #16, #17, and #18 in Exhibit E — demonstrating systematic automated harassment that entirely ignored the active dispute.
[5]INTERNAL TRACKING CODE IN SUBJECT: "SPMB2 BNAZARENO" is an internal code referencing Benmoreen Nazareno — confirming these are mass-generated automated emails linked to specific officer codes, not individualized legal communications.
— END OF EXHIBIT I —
