Republic of the Philippines

Second Judicial Region

4th Municipal Circuit Trial Court
________________________
Province of Cagayan

_________________________,
Plaintiffs,
-versus- Civil Case No. _____________
For: Unlawful Detainer with
Damages

______________________ and all

persons claiming rights under
her
Defendants.
x---------------------------------x

PRE-TRIAL BRIEF

Plaintiffs, __________________, through the undersigned

counsel, respectfully submit the following Pre-Trial Brief
pursuant to the Notice of Pre-Trial Conference issued by the
Honorable Branch Clerk of Court ________________:

BRIEF STATEMENT OF FACTS/CASE

1. _______________________________

PLAINTIFF’S ADMISSION

2. Complainant has no other facts and circumstances

to admit other than those already stated in her Complaint filed
_______________________.

PROPOSED STIPULATION OF FACTS

___________________________________________________________

POSSIBILITY TO ENTER INTO COMPROMISE AGREEMENT

3. Herein plaintiffs are willing to discuss the possibility

of entering into agreement as may be allowed by law under such

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terms and conditions mutually acceptable to all parties
concerned.

ISSUES TO BE TRIED / RESOLVED

4. The issues to be resolved in this case are:

a) Whether or not the plaintiffs are the registered

owners of the subject property;

b) Whether or not defendants only possess the

subject property as a mere lessee.

c) Whether or not defendants should vacate the

subject property due to the non-payment of
rent.

d) Whether or not defendants are liable to pay the

unpaid rentals plus interests, damages and
attorney’s fees.

WITNESSES TO BE PRESENTED

5. Plaintiffs and or their representatives will be

presented to testify and substantiate the allegations in the
complaint and likewise to identify the documents to be
presented in the course of the trial of the case.

6. _____________________________________________

MODES OF DISCOVERY

7. Herein plaintiffs hereby manifest that they are

considering to avail of the various modes of discovery as
provided for under the Rules of Court, as they may deem fit and
necessary during the course of the trial.

DOCUMENTARY EVIDENCE

8. Plaintiffs will present the following documents:

a. ________________________
b. ________________________
c. ________________________
d. ________________________
e. ________________________

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 Furthermore, plaintiffs reserve their right to present
additional evidence as the need arises or once available.

APPLICABLE LAWS

9. Pertinent provisions of the Civil Code Code, Revised

Rules of Court and existing jurisprudence there under.

AVAILABLE TRIAL DATES

10. Plaintiffs’ counsel will be available on such trial dates

mutually agreed upon during the pre-trial, subject to the
availability of the Honorable Court’s calendar.

RESPECTFULLY SUBMITTED.

____________________, September 16, 2019.

____________________
Counsel for the Plaintiffs
11/F Agustin 1 Building, F. Ortigas Jr.Road,
Ortigas Center, Pasig City.
E-mail: ___________________
Roll No. _______________
PTR NO. _____________________/Pasig City
IBP LIFETIME NO. _____________/Rizal Chapter
MCLE Compliance No. _____________
Valid Until ________________.

COPY FURNISHED:

____________________

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