VIRGINIA VALENCIA- GUILAS, Plaintiff, -Versus39820 Detainer FRANCISCA CRISTOBAL-VALENCIA and all other Person claiming rights and acting in her behalf, Defendant. x--------------------------------------------------------------x Civil case No. 09For : Unlawful


DEFENDANT, by counsel and to this Honorable Court, respectfully submits this Pre-Trial Brief compliance with the trail court’s order dated, October 22, 2010. I Defendant is willing to enter into an amicable settlement of the case, under term and condition agreeable to both parties and submit to alternative modes of dispute resolution; II

Defendant admits the following facts:

A. The paragraph 1 and 2 of the complaint.
B. The paragraph 8, complaint insofar as to the death of

defendant’s husband also admits paragraph 10, complaint, as regards the absence of plaintiff and her mother in the burial of defendant’s husband. III Issues to be resolved are the following:

A. Whether or not the plaintiff has cause of action .
B. Whether or not this Honorable Court has jurisdiction over the

subject matter of the case. C. Whether or not the plaintiff is the real party in interest.

Caloocan City By: JEREMIAH V. personal service not being practical due to the lack of messengerial personnel. TCT NO. 9(e). 2011 PEOPLE’S LAW OFFICE Counsel for the Defendant Suite 511 Victoria Building 11th Avenue . 813769/1. National Archives. PARANAQUE CITY EXPLANATION The foregoing Pre-trial Brief was served by registered mail.F. LEILANI DACANAY. 174317 issued by the Register Of Deeds of Quezon City IV Defendants reserves the right to present additional documentary evidence and witnesses in the course of the proceedings. Complaint) B. Demand letter (Annex “F” . Certification ( Annex “1”) E. Complaint) C. 1991 Revised Rule on Summary Procedure. in relation to sec. 12 and 13 Rule 70. HEVA. January 18. Complaint) D.10/Bulacan COPY FURNISHED : ATTY. 55252 PRT NO. E.A. Whether the complaint was filed harass the defendant. III The Defendant intends to present the following Documentary evidence: A. Certification to file action (Annex “E” . B.D. Whether or not the plaintiff fails to shows proof that the defendant actually received a demand letter to vacate the subject property F. Whether or not the plaintiff fails to give three (3) months’ notice in advance prior to the filing of the case in violation of Sec. Caloocan City. Whether or not the plaintiff fails to comply with Sec. Rules of Court . local Government Code on Barangay conciliation and Sec 18 and 19. VILLANUEVA ROLL NO. Respectfully submitted. 9653.. G. . No. 4129(a).26.10/Bulacan IBP NO. 0025641/1. Sinumpaang Salaysay ( Annex “G” . R.GRIMARES Counsel for the Plaintiff 48 Periquet St.28. BF HOME.

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