Republic of the Philippines

Republic of the Philippines

REGONAL TRIAL COURT
4th
Judicial Region
Branch ___, Laguna

SPOUSES TEODORICO Civil Case No. _______________

VIOVICENTE and DOMINGA
VIOVICENTE
Plaintiffs, For: Cancellation of Transfer Certificate of Title and
Deed of Absolute Sal

Versus

SPOUSES DANILO L. VIOVICENTE

and ALICE H. VIOVICENTE, THE
REGISTER OF
DEEDS CALAMBA, LAGUNA,
Defendants
x--------------------------x

PRE-TRIAL BRIEF FOR THE PLAINTIFFS

COME NOW, the Plaintiffs Teodorico Viovicente and Dominga Viovicente, by the
undersigned counsel and unto this Honorable Court, most respectfully submits their Pre-Trial Brief,
as follows:

I. POSSIBILITY OF AMICABLE SETTLEMENT

Amicable settlement is highly improbable.
II. FACTS PROPOSED FOR ADMISSION
A.) That that the plaintiffs are coerced to sign the Deed of Sale dated June 24, 1993
B) That they never signed any Deed of Sale dated December 14, 1995
c) That they never received the consideration amounting to P 111,180.00 specified
therein.
III. ISSUES TO BE RESOLVED
1. Whether or not the subject deed of sale is valid
IV. LIST OF EXHIBITS/DOCUMENTS TO BE MARKED

The plaintiff will present the following documents with reservation to present
additional documentary evidences—

EXHIBIT Nature of Documents

A Deed of Sale dated January 24, 1993
B GSIS Certification stating that Teodorico reported for work on
December 14, 1995
C GSIS Certification dated May 12, 198645 certifying that
Teodorico was granted a housing unit

1
 D GSIS Certification dated February 12, 200246 ce1tified that
Teodorico's housing loan was already fully paid on December
8, 1992 under OR No. 507693421

V. WITNESSES TO BE PRESENTED

Plaintiff will present the following witnesses with reservations to present additional
witnesses-
a) The Plaintiffs Teodorico Viovicente and Dominga Viovicente;

VI. APPLICABLE LAWS and JURISPRUDENCE

Laws on Sales and other pertinent laws.

VI. AVAILABLE TRIAL DATES OF COUNSEL TO COMPLETE EVIDENCE

PRESENTATION

Subject to the court calendar and the availability of the parties.

Other relief are just and equitable under the premises are likewise prayed for.

Calamba, Laguna, Philippines, January 20 , 2003.

ATTY. JUANA A. DELA CRUZ

Counsel for the Plaintiff
c/o Filipino & M and Associates Law Firm
Primacy Building, Calamba, Laguna
IBP No. 947555/ 1-02-03/ Calamba, Laguna
PTR No. 7150933// 1-02-03/ Calamba, Laguna
Roll No. 77777
MCLE Compliance No. IV-0079772/
March 21, 2003
Telephone No. (082) 285-7717