Republic of the Philippines

FIRST JUDICIAL MUNICIPAL REGION

REGIONAL TRIAL COURT
Bangued, Abra

BRANCH 2

HEIRS OF RODRIGO CIVIL CASE NO. 3498

TAVERNER,
Plaintiffs, FOR:

“RECOVERY OF OWNERSHIP
- versus – AND POSSESSION,
CACELLATION OF TITLE, TAX
DECLARATIONS AND OTHER
HEIR/S OF MANUEL V. DOCUMENTS WITH
RIVADA SR., DAMAGES”
Defendant.
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PRE-TRIAL BRIEF
COMES NOW, the defendant, by counsel, unto the Honorable
Court most respectfully submits her Pre-Trial Brief:

POSSIBILITY OF AMICABLE SETTLEMENT

The defendant is open to a fair and just amicable settlement

for the resolution and termination of the above entitled case.

PROPOSED STIPULATION OF FACTS

Defendant proposes to stimulate on the following:

1. The Jurisdiction of the Honorable Court;

2. That the late Manuel Rivada was survived by defendant

EMMANUEL RIVADA and AIZA RIVADA, both legitimate, surviving and
forced heirs.
3. That the subject property was originally owned by Silvestre
Gonzales, a native of Calasag, Abualan, San Juan, Abra
4. That the ownership of the subject property was transferred to
Antonio Tolentino, Silvetre’s grandson;
5. That Anotonio Tolention sold the subject property to Manuel
Rivada on May 20, 1981;
 6. That by virtue of the sale Manuel Rivada has since then been
in actual, adverse, public, continuous and peaceful possession
thereof in concept of an owner.
7. Defendant’s possession which is for more than thirty (30)
years including that of her predecessors-in-interest, made in the
concept of an owner, adverse, public, peaceful and uninterrupted

DOCUMENTARY EVIDENCE

1. Deed of Absolute Sale dated May 20, 1981;

2. Decision of Branch 1 of the Regional Trial Court of Abra in
LRC REC. NO. N-56982 COURT CASE NO. N-271;

3. Original Certificate of Title No. 0-289;

Defendant reserves the marking of additional documentary
exhibits as trial proceeds.

WITNESSES TO BE PRESENTED

Defendant will present at least six (6) witnesses to take the

witness stand. Said witness will require at least one (1) calendar day
each for their direct testimonies.
Defendant reserves the presentation of additional witnesses
when warranted and necessary.

RESPECTFULLY SUBMITTED
Bangued, Abra.
October 19, 2017.

HP. BIGORNIA LAW OFFICE

2nd Floor D. Bigornia Bldg, Rizal St.
Zone 7, Bangued, Abra (2800)

By:
HAMILCAR P. BIGORNIA
Counsel for Defendant
ROLL NO. 47119 / IBP LIFE O.R. NO. 4289
MCLE Compliance No. V - 0008469
PTR NO. 323061-03-18/Bangued, Abra
Copy furnished:
ATTY. RONNIE RAPANUT
Dudley S Lara Bldg., Florentino, St.,
Vigan City, Ilocos Sur

REGISTERED MAIL WITH RETURN CARD

EXPLANATION

A copy of this PRE-TRIAL BRIEF was furnished to the plaintiffs thru their
counsel by registered mail with return card due to distance and lack of
personnel to effect personal delivery.