Republic of the Philippines

Fourth Judicial Region

MUNICIPAL TRIAL COURT IN CITIES
Branch 1
___________________

xxxxxxxxxxxxxxxxxxxxxxxx, Civil Case No.

For: PARTITION

Plaintiffs,

- versus -

Yyyyyyyyyyyyyyyyyyyy,
Defendants.
x-----------------------------x

MOTION TO AMEND/CORRECT
PRE-TRIAL ORDER
DEFENDANTS, by counsel, unto this Honorable Court, most respectfully
avers THAT:

1. During the 22 January 2021 Pre-Trial, the parties stipulated as to the

facts involved in this Case;

2. The undersigned, through inadvertence, misunderstood the meaning of

the third stipulation that “xxxxxxx”;

3. Such misunderstanding was primarily caused by the undersigned’s

reliance on the earlier admissions in the Complaint and Answer;

4. The admission by the Plaintiffs in the Complaint, Paragraph 2, page 1,

provides:

“.”

5. The aforesaid allegation was admitted by the Defendants in its ANSWER

with COUNTERCLAIM received by the Honorable Court on xxxxx:
MOTION TO AMEND/CORRECT PRE-TRIAL ORDER
Xxxx v. yyyyy
Civil Case No.xxxxx
Page 2 of 2

6. That the Grant of such Amendment/Correction will not prejudice the

Plaintiffs as the same will conform to the earlier admissions in the
pleadings (Complaint and Answer), and the evidence on Record;

7. Thus, the Defendants, through the undersigned Counsel, denies the

third stipulation “xxxxx”;

PRAYER

WHEREFORE, in the interest of substantial justice, it is most respectfully

prayed before this Honorable Court that the Pre-Trial Order dated 22 January
2021 be amended by deleting item number 3) in the list of admitted or
stipulated facts.

Respectfully submitted.