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Pre-Trial Brief

1. The defendant is willing to enter into an amicable settlement of the case on just and equitable grounds. 2. The defendant admits only the facts stated in their answer and that the subject land is covered by a specific tax declaration number. 3. The main issue is whether the case will be dismissed and if the defendant is the rightful possessor and owner of the disputed property.

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465 views3 pages

Pre-Trial Brief

1. The defendant is willing to enter into an amicable settlement of the case on just and equitable grounds. 2. The defendant admits only the facts stated in their answer and that the subject land is covered by a specific tax declaration number. 3. The main issue is whether the case will be dismissed and if the defendant is the rightful possessor and owner of the disputed property.

Uploaded by

Pj Tigniman
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

Republic of the Philippines

Second Judicial Region


MUNICIPAL CIRCUIT TRIAL COURT
Banaue-Hungduan-Mayoyao
Banaue, Ifugao

LUCIANO HAGITAN CIVIL CASE NO. 791


Plaintiff,

-versus- FOR: RECOVERY OF POSSESSION


And OWNERSHIP with PRAYER
ANA ALBERTO and all other FOR DAMAGES
Persons claiming under her,
Behalf,
Defendants.
X---------------------------------------------------X

DEFENDANT’S PRE – TRIAL BRIEF

Defendant, by counsel and to this Honorable Court, respectfully


submits this Pre – Trial Brief and for this purpose states THAT:

I
AMICABLE SETTLEMENT

Defendant is willing to enter into an amicable settlement of the


case on just and equitable grounds.

II
ADMITTED FACTS
1. Defendant only admits the facts stated in her Answer, as to the
personal circumstances of the parties.

2. Subject to a concrete proposal for stipulation of additional facts


from plaintiff during pre-trial or even thereafter, defendant admits no
other facts from the Complaint.

III
PROPOSED STIPULATION OF FACTS

1. That the subject land is covered by Tax Declaration No. 2014-


070009.

Page 1|3
IV
ISSUES

Whether or not the case be dismissed and/or the defendant is the


rightful possessor and owner of the property.

V
DOCUMENTS OR EXHIBITS TO BE PRESENTED

1. Affidavits of the witnesses for the Defendant;

2. Pictures of existing structures on the land in dispute;

3. Defendant reserves the right to present any and all


documentary evidence which shall become relevant to rebut
plaintiff’s claims in the course of trial as well as any other witnesses
whose testimony will become relevant to belie plaintiff’s witnesses, if
necessary.

VI
WITNESSES

1. Defendant herself, who will testify on the true circumstances


leading to the filing of the suit against him;

2. Defendant reserves the right to present additional witnesses in


the course of trial as may be necessary

RESPECTFULLY SUBMITTED.

Lagawe, Ifugao this 1st day of March 2019.

ATTY. PRESLEY JOHN L. NAMINGIT


Counsel for Petitioner
Roll No. 69260 – May 31, 2017
IBP No. 1065417 – Jan. 3, 2019
PTR No. 6048871 – Jan. 3, 2019
MCLE Compliance Exempt (New Lawyer)

Page 2|3
Copy Furnished:

Atty. Aguinaya D. Uyan-Catiling


Counsel for the Plaintiff
Public Attorney’s Office
Banaue, Ifugao

EXPLANATION

A copy of the Defendant’s Pre-Trial Brief is furnished to the


counsel for Plaintiff thru registered mail due to distance and lack of
personnel to deliver the same.

Thank you.

Presley John L. Namingit

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