Republic of the Philippines

REGIONAL TRIAL COURT

5TH Judicial Region
Branch 19
Naga City

PETER JOHN ADEMER OROSCO,

Plaintiff,

- versus - Civil Case No. XXXXXXX

For: Collection of sum of money

ABELARDO ASPE,
Defendants.

x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x

PRE-TRIAL BRIEF

Plaintiff through counsel, respectfully submits his Pre-Trial Brief, as follows:

I. ON THE POSSIBILITY OF AMICABLE SETTLEMENT:

Plaintiff is open to a reasonable proposal to amicably settle this case.

II. BRIEF STATEMENT OF PLAINTIFF’S COMPLAINT:

Plaintiff is claiming that the amount of the principal loan including interest, attorney’s

fees and litigation expenses when defendant failed to pay his obligation on its due date despite

repeated demands.

III. FACTS FOR ADMISSION:

1. Identity of the parties;

2. Genuineness and due execution of the promissory note, dated January 10, 2014 in
the amount of P 500, 000.00, executed by defendant in favor of the plaintiff;
3. That the loan obligation evidenced by the promissory note has already become due
and demandable;
4. That repeated demands were made to defendant, however until now said
obligation has not been paid;
 5. That the plaintiff incurred incidental expenses and damages by reason of the filing
of this case.

IV. ISSUES TO BE TRIED

1. Whether or not defendant is liable to plaintiff’s claim? If so, how much?

2. Damages

V. WITNESSES FOR THE PLAINTIFF

At least 2 witnesses to substantiate plaintiff’s claim.

VI. AVAILABLE TRIAL DATES

The dates will just be supplied during the pre-trial hearing.

WHEREFORE it is respectfully prayed that this pre-trial hearing be admitted.

RESPECTFULLY SUBMITTED.

Naga City. 05 May 2015

NEIL RYAN R. DECLARO

Counsel for the Plaintiff

IBP No. XXXXXXX

December 15, 2015
PTR No. XXXXX
MCLE Exemption No. _____
Roll No. XXXX
Copy Furnished:

Atty. Dorothy C. Arevalo

Counsel for the Defendant
3rd Floor PNB Bldg, Naga City