Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

SECOND JUDICIAL REGION
BRANCH I
Tuguegarao City

ANICIA CARODAN PASICOLAN CIVIL CASE NO. 3251

Plaintiff,

FOR:

“REVOCATION OF DONATION
RECONVEYANCE OF REAL
ESTATE ANNULMENT OF TCT
Versus
NO. T-159357 WITH
APPLICATION FOR
TEMPORARY RESTRAINING
ORDER AND PRELIMINARY
INJUNCTION”

ELVIRA MENDOZA PASICOLAN

ET. AL.
Defendants.

x-------------------------------------x

DEFENDANT’S PRE-TRIAL BRIEF

DEFENDANT ELVIRA MENDOZA Y PASICOLAN, assisted by the

Public Attorney’s Office, through the undersigned counsel, most
respectfully submits this pre-trial brief:

PROSPECT OF AMICABLE SETTLEMENT

Defendant, without necessarily admitting liability and waiving her

rights is amenable to an amicable settlement or alternative dispute
resolution upon such terms as are justifiable and acceptable.

PROPOSAL FOR STIPULATION

1. To be submitted during the pre-trial.

ISSUES TO BE RESOLVED

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 1. To be submitted during the pre-trial.

AVAILMENT OF DISCOVERY PROCEDURES

Defendants intend to avail herself of discovery procedures and or

referral to commissioners.

DOCUMENTS TO BE PRESENTED

1. Exhibit 1- Deed of Donation dated February 26, 2007

2. Exhibit 2- TCT No. T-159357 dated March 6, 2007
3. Exhibit 3- Declaration of Real Property in the name of Regino
Pasicolan
4. Exhibit 4- Receipts of Real Property Tax payment
5. Exhibit 5- Subdivision Plan of Lot No. 2059
6. Exhibit 6- Minutes of Confrontation Proceedings dated
January 23, 2020
7. Exhibit 7-Photos of the property of the defendant

Defendants reserve the right to present, mark and offer

additional documentary exhibits, if necessary during the course of trial.

NUMBER OF WITNESSES

Defendant will present the following witnesses, to wit:

1. Elvira Pasicolan- to testify on her defenses as alleged in the

Answer
2. Engr. Moises Cusipag- to testify on the Subdivision Plan he
prepared.
3. Brgy Capt. Artemio Tallud- to testify on the Certificate to File
Action and the Minutes of Confrontation proceedings dated
January 23, 2020.
4. Lilibeth Bangayan-to corroborate the testimony of defendant

Defendants reserve the right to present additional witnesses

during trial.

AVAILABLE TRIAL DATES

Counsel for Defendants will be available for trial on dates to be

mutually agreed upon with plaintiff’s counsel during the pre-trial
conference.

RESPECTFULLY SUBMITTED.

Tuguegarao City, Cagayan. January 14, 2020

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 PUBLIC ATTORNEY’S OFFICE
Department of Justice
Tuguegarao City, Cagayan

By:

MARYDINE CAMBRI MERCADO

Public Attorney II
Counsel for the Defendant
Roll No. 64356
IBP No. 030652, Cagayan
MCLE No. VI-0025998 until April 14, 2022

Copy furnished:

Atty. Glenn Macabadbad

Luna St., People’s Gymnasium,
Tuguegarao City, Cagayan

EXPLANATION

The foregoing pre-trial brief is served on the plaintiff’s counsel

through registered mail due to distance.

MARYDINE CAMBRI MERCADO

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