Republic of the Philippines

Sixth Judicial Region

REGIONAL TRIAL COURT
Branch___
Iloilo City
Spouses Marcus and
Maureen McPoyle,
Plaintiffs.

Civil Case No. 6379-98

For Damages

-versusDinagat Island Hotel and

Resort Corporation
(DIHRC),
Defendant.
x-----------------------------------------------x
PRE-TRIAL BRIEF OF THE DEFENSE
DEFENDANT , through the undersigned counsel, before this
Honorable Court, most respectfully submit this Pre-Trial Brief:
SUMMARY OF ADMITTED FACTS
AND PROPOSED STIPULATION OF FACTS
The defendant admits the following:
1. That the plaintiffs, together with family and friends, were
guests at the defendant corporations hotel and resort;
2. That the plaintiffs, after the celebration of their wedding,
found that their room was unlawfully entered and that several
personal belongings were missing;
3. That the plaintiffs reported the incident to the management
and requested for a copy of the cctv footage;
4. The date, place and time of the incident, which was February
14, 2016 at about 9:00 in the evening and at their hotel room Dinagat
Island Hotel and Resort, 6750 Hilay St. Dinagat, Dinagat Islands

EVIDENCE FOR MARKINGS

1. Check-in information of the plaintiffs;
2. Guest List on the day of the incident;
2. Waiver of Liability as regards loss or damage to personal
belongings of guests;
ISSUES
1. Whether or not the defendant may be made liable for the loss
suffered by the plaintiff-spouses
2. Whether or not the defendant may be made to pay for damages
as prayed for by the plaintiff-spouses
WITNESSES
1. Manolo de Castro, security guard on duty on the day of the
happening of the incident, to testify on what he was does to ensure
the security within the hotel premises;
2. Biboy Ramirez, security personnel on duty on the day of the
happening of the incident, to testify on the security measures taken by
the hotel;
3. Louisa Mercado, manager on duty on the day of the
happening of the incident, to testify on the hotel policies on matters
such as the incident;
4. Katrina Abella, a hotel guest whose hotel room was across
the room of the plaintiffs, to testify on what she saw and heard in
connection to the incident.

TRIAL DATES
Specifically all Wednesdays or Fridays of the month, with the
regular appearance of the undersigned counsels before this
Honorable Court.
RESPECTFULLY SUBMITTED.
Municipality of Dinagat, Dinagat Islands Philippines, this 8th day of
March, 2016.
AMZ LAW
Counsel for the Defendant
Rm. 2115 Dinagat Towers Bldg.,
Municipality of Dinagat, Dinagat Islands
Atty. Jezreel Zapanta
PTR No. 98764354:8-98-54:B.C.
IBP No. 4589987:3-99-54:B.C.
Roll No. 396422:2-10-85
Atty. Kelsey Mendoza
PTR No. 9102241:10-92-34:B.C.
IBP No. 3753925:4-96-24:B.C.
Roll No. 425982:8-27-88
Atty. Tanya L. Andrade
PTR No. 91083452:2-88-64:B.C.
IBP No. 4222368:6-98-54:B.C.
Roll No. 592357:4-26-98