Republic of the Philippines

REGIONAL TRIAL COURT

Third Judicial Region
Malolos City, Bulacan
Branch XI

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Plainti
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Civil Case No. 1234
- versus - For: Recovery of Possesion

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Defenda
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PRE-TRIAL BRIEF

COMES NOW, Defendant through the undersigned counsel

and unto this Honorable Court, most respectfully submits this Pre-
Trial Brief, to wit:

I. AMICABLE SETTLEMENT

The Defendant is willing to enter into an amicable settlement

which is fair, just and equitable.

II. PROPOSED STIPULATION OF FACTS

1. The Defendants, bbbb, are the lawful children and heir of

Spouses Leonardo and Yolanda Gonzales;

2. The Defendants, bbb, together with their parents were in

possession and living in the property subject matter of
the complaint as early as 2001;

3. That it is the parents of the defendants, bbb, who caused

the building of the house erected in the property subject
matter of the complaint;
 4. That Complainants was never in PHYSICAL POSSESION
of the property subject matter of the complaint;

III. ISSUE

1. Whether or not the defendants bbb are the owners of the

subject property of this complaint and are entitled to the
legal possession thereof;

2. Whether or not Defendants are entitled to Actual, Moral

and Exemplary damages.

IV. WITNESSES

Defendants, bbb, will be presented as witnesses to disprove

the claims of the complainant. Defendants, Hart Gonzales
and Hanz Gonzales, prays that they be allowed to present
additional witnesses during the course of the trial for good
cause shown;

V. DOCUMENTS

EXHIBITS NATURE

“1 to 1-B” Conditional Settlement Commitment

between bbb and BALIKATAN
HOUSING FINANCE, INC.;

“2 to 2A”` Deed of Transfer of Rights between

bbbb;

“3 to 3-E” Payment Receipts

Defendants, bbb, prays that they be allowed to present and

mark additional evidence during the course of the trial for good
cause shown

VI. AVAILABLE TRIAL DATES

 The undersigned counsel, from the bbb, is available for hearing
before this Honorable Court every Wednesday (morning and
afternoon), and Friday (morning).

WHEREFORE, premises considered it is respectfully prayed before

this Honorable Court that the foregoing pre-trial brief be admitted
and given due course in the pre-trial proceedings of this case.

Other relief and remedies just and equitable under the circumstances
are likewise prayed for.

Respectfully submitted.