Republic of the Philippines

5th MCTC Tuba-Sablan

Tuba, Benguet

NORMA MADIGUID

Plaintiff.

-versus- CIVIL CASE NO. 12345

For: Unlawful Detainer

MARIA C. ABANCE

Defendant.
x x

PRE-TRIAL BRIEF
PLAINTIFF, by counsel, respectfully submits his Pre-Trial Brief, as follows:
I. WILLINGNESS TO ENTER INTO AN AMICABLE SETTLEMENT AND POSSIBLE
TERMS OF ANY SUCH SETTLEMENT
1. Plaintiff is open to settling this dispute amicably, subject to a concrete proposal
that is fair and reasonable and a reciprocal manifestation of openness from defendant.

II. BRIEF STATEMENT OF CLAIMS AND DEFENSES

1. The defendant failed to pay the agreed rental from January 2022 up to the present and
is continuously occupying the same although she failed to renew the contract of lease.
Even after several and repeated demands, the defendant continues to illegally occupy the
subject property;
2. The plaintiff now institutes this action for unlawful detainer for the continued
possession by the defendant of the subject property is prejudicial to the rights of the
plaintiff.

III. FACTS AND OTHER MATTERS ADMITTED BY THE PARTIES

1. Plaintiff admits the personal circumstances of the parties as stated in the compliant and
answer.
2. Plaintiff further admits the facts stated in her complaint only.

IV. ISSUES TO BE TRIED

1. Whether or not defendant should be ejected from the subject property.
V. EXHIBITS MARKED AS DOCUMENTS TO BE PRESENTED
Exhibit A- A copy of the TCT in the name off the plaintiff.
Exhibit B- A copy of the Contract of Lease between plaintiff and defendant last
September 2, 2021
Exhibit C- A copy of the demand letter by the plaintiff to the defendant.
Exhibit D- Judicial Affidavit of the Plaintiff.
The plaintiff reserves her right to present other documents not herein listed as may be
deemed necessary.

VI. WITNESSES TO BE PRESENTED

1. The plaintiff himself to testify regarding the unlawful continued possession by the
defendant of the subject property;
2. The defendant reserves the right to present other witnesses not herein enumerated as
deemed necessary.

VII. AVAILABLE TRIAL DATES

The plaintiff would depend on the dates agreed upon during the pre-trial.

RESPECTFULLY SUBMITTED. Tuba, Benguet, May 7, 2022.

ATTY. JEVAN B. DICTAAN

Counsel for the Plaintiff
Notary Public until December 31, 2022
PTR No. 1234567
IBP No. 58637
Roll No. 123456
MCLE Compliance No. 000123

Copy Furnished:

ATTY. FAUSTO MATEO JR. (Counsel for the Accused)

Unit 2, XYZ Bldg. Poblacion, Tuba

EXPLANATION
A copy of this pleading is served via registered mail instead of personal service on
the adverse counsel due to the the lack of field staff of undersigned counsel at this time.

ATTY. JEVAN B. DICTAAN