REPUBLIC OF THE PHILIPPINES

National Capital Judicial Region

Regional Trial Court
Branch ___, QUEZON CITY

JUANCY DE OCAMPO
Plaintiff,

- versus - Civil Case #

1234567
Complaint for payment of damages

LEONARD O. PUA,
Defendant.
x--------------------------------------x

PRETRIAL BRIEF

PLAINTIFF, JUANCY DE OCAMPO, assisted by the undersigned

counsel, and unto this Honorable court, respectfully submits this
Pre-Trial Brief and alleges:

POSSIBILITY OF AMICABLE SETTLEMENT

Plaintiff is open and willing to discuss the possibility of an

amicable settlement based on fair and reasonable terms
acceptable to both parties.
 BRIEF SUMMARY OF

ADMISSIONS BY RESPONDENT

Plaintiff is only willing to admit matters he admitted in his

complaint-affidavit.

I S S U E S:

1. WHETHER OR NOT DEFENDANT IS GUILTY OF NEGLIGENCE

AND RECKLESSNESS IN DRIVING HIS VEHICLE?
2. WHETHER OR NOT THE RESPONDENT IS LIABLE FOR
PAYMENT OF ACTUAL AND MORAL DAMAGES DUE TO QUASI-
DELICT?

PROPOSED STIPULATION OF FACTS

1. That on December 19, 2016 at around 7:00 in the morning

, the plaintiff was driving his white Honda CRV with plate
number ABC 148 on the way to his office in Makati.
2. That the plaintiffs usual route was through the Epifanio de
los Santos Avenue southbound (EDSA) from Kamuning to
Ayala;;
3. That while the plaintiff was traversing EDSA on a
reasonable amount of speed considering EDSA traffic and
when he has already reached the Ortigas flyover, a pink
Toyota Vios car with plate number GTG 321 being driven
by the defendant was fast approaching from behind;
4. That the defendant was driving too fast and to near to the
plaintiffs cars rear bumper;
 5. That the defendants car hit the rear bumper of the
plaintiffs car when the plaintiff slowed down;
6. That the plaintiff and the defendant was not able to reach
a settlement on the day of the incident.

DOCUMENTS TO BE PRESENTED AND THEIR PURPOSE

1. Affidavit complaint of Juancy De Ocampo

Purpose: To prove the material allegations of the
complaint

2. Land Registration Office Certificate of Registration and

Official Receipt of the white Honda CRV driven by the
plaintiff.
Purpose: To prove the ownership and due
registration of the vehicle of the plaintiff
3. Photograph of the defendants car, on the day of the
happening of the tortious act, showing the plate number
Purpose- To provide proof of the actual plate
number of the defendants car and that the car
was violating the color coding scheme during that
time.

WITNESSES

1. JUANCY DE OCAMPO
2. ELTON TOLENTINO
Purpose: To prove the material allegations of the
complaint.
 AVAILABLE TRIAL DATES

Actual Trial dates may be stipulated on.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed

that the foregoing Pre-Trial Brief be admitted.

All other reliefs just and equitable are prayed for.

City of Quezon City, February 20, 2017.

By :

DOMINIC LOREN R. AGATEP

Counsel for the Plaintiff
PHIL. BAR ROLL NO. 11111
MCLE Compliance No. V-0001111/05-14-2015
PTR NO. 0111111/01-05-2015/Q.C.
IBP NO. 111111/01-05-2015/Q.C.

Copy furnished:

ATTY. MARIE ELLA ROCO

Counsel for the plaintiff
PHIL. BAR ROLL NO. 112222
MCLE Compliance No. V-0001112/05-14-2015
PTR NO. 0111112/01-05-2015/Q.C.
IBP NO. 111112/01-05-2015/Q.C