Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Tanjay City

BALTAZARA D. MORQUEDA,
Plaintiff, Civil Case No. 1187
For: EJECTMENT

-versus-

LYDIA DURA, ET AL.

Defendants.

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PRE-TRIAL BRIEF

Plaintiff, through counsel, most respectfully submit their Pre-Trial Brief, to

wit:

STATEMENT OF THE CASE

POSSIBLE AMICABLE SETTLEMENT

PROPOSALS FOR ADMISSION

1. Identity of the parties;

2. The residential building of the subject matter of this case is constructed
on a Lot No. 2848 owned by the plaintiff;
3. The house was declared for taxation purposes under the name of Lydia
Duran;
4. Lydia Duran electricity installed on the house and has been a registered
consumer of Negros Oriental II Electric Cooperative;
5. Plaintiff is an attorney-in-fact of Lydia Duran by virtue of an special
power of attorney made and executed on August 19, 2017.

ISSUES TO BE RESOLVED
 DOCUMENTARY EVIDENCES

1. Exhibit A: Declaration of Real Property from the City Assessor

2. Exhibit B: Special Power of Attorney duly made and executed by Delma
R. Ganaden
3. Exhibit C: Final letter to vacate executed by Mrs. Baltazara D. Morquida
4. Exhibit D: Registry Receipts and Return Receipts
5. Exhibit E: Certification to File Action dated October 27, 2016
6. Exhibit F Judicial Affidavit of Baltazara D. Morqueda
7. Exhibit G dicial Affidavit of Rufilito Roy C. Torres
8. Judicial Affidavit of Isabelita A. Alcantara
9. Judicial Affidavit of Rebecca R. Duran

Purpose of the Offer:

Exhibit A - to show that Plaintiff is the owner of the Residential Building

constructed on Lot 2848
Exhibit B - to show that Plaintiff was given consent by Delma r.
GANADEN to construct/build any house on Lot No. 2848, secure building permit
and among others;

Exhibit C- to show Plaintiff made and executed a demand letter to vacate

Exhibit D- Plaintiff
Exhibit E- to show that this case underwent barangay conciliation
proceeding but no settlement was obtained
Exhibit F- to show that this case underwent barangay conciliation
proceeding was obtained