Republic of the Philippines

METROPOLITAN TRIAL COURT

National Capital Judicial Region
City of Manila
Branch 88

ARIANA GRANDE,
Plaintiff,
CIVIL
CASE No. CV-10-12345
-versus- FOR:
Unlawful Detainer

BRUNO MARS,
Defendant.

x-----------------------------------x

PRE-TRIAL BRIEF
(For the Plaintiff)

PLAINTIFF, through counsel, unto this Honorable court most

respectfully submits the following Pre-trial Brief:

I
BRIEF STATEMENT OF THE CASE

This is an action for UNLAWFUL DETAINER.

Plaintiff is the lawful owner of a land over which an

apartment had been constructed located 789 Road
13,Bagong Pag-asa, Sampaloc, Manila and resides at 123
Road 1, Bagong Pag-asa, Sampaloc,Manila while defendant is
a resident of 456 Ayala Avenue, Makati City. Sometime in
October 2011, plaintiff and defendant agreed to enter into a
lease agreement. By virtue of a contract of lease, the
plaintiff leased unto the defendant the aforesaid apartment
for a consideration of P5,000.00 a month as rental to be paid
within the first ten (10) days of each month starting
November 3, 2011. Defendant failed to pay the agreed rental
for several months starting June 1, 2016 up to the present.
Letter of demand was sent to defendant and despite said
letter of demand which was repeated by oral demands, the

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 defendant failed and still refused to pay the agreed amount
of rentals and to vacate the apartment; thus, this action.

II
WILLINGNESS TO ENTER INTO AMICABLE SETTLEMENT OR
ALTERNATIVE MODES OF DISPUTE RESOLUTION

Plaintiff is open to amicable settlement or alternative modes of

dispute resolution upon mutually acceptable terms and
conditions.

III
SUMMARY OF ADMITTED FACTS

Plaintiffs admissions are limited to those matters that are

alleged in her complaint.

IV
PROPOSED STIPULATIONS

Plaintiff hereby proposes that Defendant admits:

1. That he contracted a lease agreement and failed to pay his
monthly rentals from June 2016 up to present.
2. That he refused to pay his obligations despite repeated
demands.
3. That he refused to vacate the apartment in question.

V
ISSUE TO BE RESOLVED

1. Whether or not defendant contracted a lease agreement and

failed to pay his monthly rentals from June 2016 up to
present?
2. Whether or not defendant refused to pay his obligations
despite repeated demands?

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 3. Whether or not defendant refused to vacate the apartment
in question?

VI
DOCUMENTARY EXHIBITS

1.) Owners Copy of Transfer Certificate of Title No.

12345678.

2.) Contract of Lease entered between Complainant and

Defendant, executed on November 3, 2011.

3.) Demand Letter to vacate the apartment which was

personally delivered to and received by the defendant as
shown in the registry return receipt dated October 1, 2016.

VII
DISCOVERY PROCEDURES

Plaintiff is willing to avail of discovery procedures necessary for

expedient resolution of the issues involved.

VIII
NAMES OF WITNESSES
AND THE SUBSTANCE OF THEIR TESTIMONIES

1. Plaintiff who shall testify on the material allegations of his

complaint;

2. Mr. Raul Robles, liaison officer of Cabiguen & Badajos Law

Office, who personally delivered the Demand Letter to the
defendant.

Plaintiff reserves the right to present the Judicial Affidavit of

witness Raul Robles to prove the allegations in her complaint.

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 IX
APPLICABLE LAWS AND JURISPRUDENCE

1. Arts. 1657 and 1673 NCC

Respectfully submitted.

Manila, 14 February 2017.

CAYEN C. CABIGUEN
IBP No. 987654; 01/20/2017- Manila
PTR No. 54321; 02/18/2017- Manila
Roll No. 112083; 11/20/2010
MCLE No. 4-321; 02/08/17