Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Branch 25
Iloilo City

REYNOLD G. TANZA,
Plaintiff,
Civil Case No. 324
-versus- FOR: Unlawful Detainer

ARDIE JAY F. DAVIDE,

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 August 2014 up to
the present and is continuously occupying the same although he 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 institute 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 his 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 machine copy of the Contract of Lease between plaintiff

and defendant last April 30, 2011.

Exhibit B – A machine copy of the demand letters by the plaintiff to

the defendant.

The plaintiff reserves his 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. 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.

Iloilo City, March 25, 2015.

ATTY. VINCENT ENRIQUE A. VARONA

Counsel for the Plaintiff
Varona Law Office, Alta Tierra Village, Jaro, Iloilo City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Iloilo City
IBP NO. 123456, 01/04/14, Iloilo City
MCLE Comp. No. IV-0009876, 01/02/14

COPY FURNISHED:
BY PERSONAL SERVICE

ATTY. MA. CASSIE JEAN D. DOLDUCO

Counsel for the Defendant
Dolduco Law Office, Mission Extension Street, Lapaz, Iloilo City
Received on March 26, 2015