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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF BATANGAS


FOURTH JUDICIAL REGION
BRANCH ____
BATANGAS CITY
KRIS DE LAS ALAS,
Plaintiff,
-versus-

CIVIL CASE NO.__________


For Sum of Money

BEA GONZAGA,
Defendant.
x--------------------------------------------x
PRE-TRIAL BRIEF
(For the Plaintiff)
PLAINTIFF, through counsel, unto this Honorable court most respectfully submits
the following Pre-trial Brief:
I
BRIEF STATEMENT OF THE CASE
This is an action for Collection of Sum of Money.
Plaintiff is the owner of lending business located at Bauan, Batangas and resides
at Sta. Rita, Batangas while defendant is a resident of San Jose, Batangas. Sometime in
12 December 2011, plaintiff granted a loan to defendant in the amount of P 800,000.00
which defendant promised to pay within the period of one year in 12 equal monthly
installments at the rate of 5% stipulated monthly interest in accordance with the terms
and conditions of the promissory note executed by defendant. Of the said obligation, no
payment has been made by defendant to this date despite repeated demands and other
earnest and diligent efforts of plaintiff to collect payment of the said loan; thus, this
action.
II
WILLINGNESS TO ENTER INTO AMICABLE SETTLEMENT OR
ALTERNATIVE MODES OF DISPUTE RESOLUTION
Plaintiff is open to amicable settlement or alternative modes of dispute resolution upon
mutually acceptable terms and conditions.

III
SUMMARY OF ADMITTED FACTS
Plaintiffs admissions are limited to those matters that are alleged in her complaint.
IV
PROPOSED STIPULATIONS
Plaintiff hereby proposes that Defendant admits:
1. That she contracted a cash loan from plaintiff in the amount of P 800,000.00;
2. That she voluntarily executed the promissory note attached in the complaint in favor
of plaintiff by reason of the loan mentioned above;
3. That of the said loan, no payment has been made by her to this date;
4. That she personally signed and received the Notice of Non-payment from plaintiff.
V
ISSUE TO BE RESOLVED
1. Whether or not defendant voluntarily executed the promissory note attached in the
complaint on account of defendants indebtedness?
2. Whether or not Defendant is liable under the terms of the said promissory note?
VI
DOCUMENTARY EXHIBITS
1. Promissory note executed by Defendant on 12 December 2011;
2. Notice of Non-payment with a demand to pay dated 11 June 2014 which
Defendant received on 12 June 2014;
3. Respective Judicial Affidavits of witnesses.
VII
DISCOVERY PROCEDURES
Plaintiff is willing to avail of discovery procedures necessary for expedient resolution
of the issues involved.
VIII
NAMES OF WITNESSES
AND THE SUBSTANCE OF THEIR TESTIMONIES
1. Plaintiff who shall testify on the material allegations of her complaint;
2. Mr. Krisanto Alcaraz, plaintiffs collector, who shall testify as to the non-payment
of defendant despite several demands from plaintiff;
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3. Ms. Elsa Rodriguez who shall testify as to the details of the loan agreement such
as but not limited to the amount thereof, the amount of cash actually received by
defendant;
Plaintiff reserves the right to present the Judicial Affidavits of witnesses Lamberto
Lizada and Gerard Castillo to prove the allegations in her complaint.
IX
APPLICABLE LAWS AND JURISPRUDENCE
1. Arts. 1159, 1170, NCC

Respectfully submitted.
Batangas City, 4 August 2014
(SGD.) NOLI SANCHEZ
Notary Public
Until 31 December 2014
PTR No. 123456 / 01-04-14 / Batangas City
IBP No. 123456 / 01-17-14 / Batangas City
MCLE Compliance No. IV
123456 / 18 June 2014
Roll No. 123456