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Republic of the Philippines

Municipal Trial Court in Cities


Tacloban City
Branch 1

PEDRO SANTOS,
Plaintiff,
CIVIL CASE No.12345
-versus- FOR: Unlawful Detainer

JUAN CRUZ,
Defendant.

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

PRE-TRIAL BRIEF

PLAINTIFF, by counsel, respectfully submits his Pre-Trial Brief,


as follows:

I. WILLINGNESS TO ENTER INTO AN AMICABLE SETTLEMENT


AND POSSIBLE TERMS OF ANY SUCH SETTLEMENT

1. Plaintiff is open to settling this dispute amicably, subject to a


concrete proposal that is fair and reasonable and a reciprocal
manifestation of openness from defendant.

II. BRIEF STATEMENT OF CLAIMS AND DEFENSES

1. The defendant failed to pay the agreed rental from May 2019 up
to the present and is continuously occupying the same although
he failed to renew the contract of lease. Even after several and
repeated demands, the defendant continues to illegally occupy
the subject property;

2. The plaintiff now institutes this action for unlawful detainer for
the continued possession by the defendant of the subject
property is prejudicial to the rights of the plaintiff.

III. FACTS AND OTHER MATTERS ADMITTED BY THE PARTIES


1. Plaintiff admits the personal circumstances of the parties as
stated in the compliant and answer.

2. Plaintiff further admits the facts stated in his complaint only.

IV. ISSUES TO BE TRIED

1. Whether or not defendant should be ejected from the subject


property.

V. EXHIBITS MARKED AS DOCUMENTS TO BE PRESENTED

Exhibit A - A copy of the Contract of Lease between plaintiff


and defendant last March 04, 2019.

Exhibit B – A copy of the demand letter by the plaintiff to the


defendant.

The plaintiff reserves his right to present other documents not


herein listed as may be deemed necessary.

VI. WITNESSES TO BE PRESENTED

1. The plaintiff himself – to testify regarding the unlawful continued


possession by the defendant of the subject property;

2. Defendant reserves the right to present other witnesses not


herein enumerated as deemed necessary.

VII. AVAILABLE TRIAL DATES

The plaintiff would depend on the dates agreed upon during the
pre-trial.
RESPECTFULLY SUBMITTED.

Tacloban City, July 5, 2019.

ATTY. MARIA REYES


Counsel for the Plaintiff
Roll No. 125656
IBP No. 64139, issued
on January 2015 at
Tacloban City
PTR No. 3294 issued
On July 2016 at
Tacloban City

COPY FURNISHED:

ATTY. JOSE RAMOS


Counsel for the Defendant
Roll No. 45678
IBP No. 17493, issued on
January 2015 at Tacloban City
PTR No. 8719 issued on
July 2016 at Tacloban City

EXPLANATION

A copy of this pleading is served via registered mail instead of


personal service on the adverse counsel due to the distance of his
law office address and the lack of field staff of undersigned counsel at
this time.

ATTY. MARIA REYES