REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 55
Pasig City

Alden Ricardo,
Plaintiff,

Civil Case No. 1029

vs For: Collection of Sum of Money

Maine Menchavez,
Defendants,
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PRE-TRIAL BRIEF

Plaintiff, through counsel, unto this Honorable Court, respectfully

submits the following:

A. Willingness to enter into an amicable settlement

Plaintiff is willing to amicably settle the case based on terms that are
beneficial to both parties

B. Statement of Proposed Facts

1. That on 6 March 2019, Maine Menchavez and Alden Ricardo entered into a
“Loan Agreement” where herein defendant Ricardo borrowed Php600,000
which was secured with a Promissory Note on the same date.
2. That under the “Loan Agreement”, payment shall be made in ten (1)
installments starting from May 6, 2020 to February 6, 2020, and failure to
pay any of the installments shall make the Php600,000 amount due and
demandable.
3. That on 6 June 2019, no payment was made.
4. That herein plaintiff Maine Menchavez personally went to the defendant’s
residence on 8 June 2019 to demand payment but the person residing there
told the plaintiff that Mr. Alden Ricardo has not been living there for three
(3) weeks.
5. That three demand letters were sent to Mr. Ricardo, but to no avail.
 C. Issues to be tried
1. Whether or not the “Loan Agreement” was valid
2. Whether or not herein defendant is liable for the amount of “P600,000”
specified in the Loan Agreement

D. Witnesses to be presented
The plaintiff intends to present four witness, namely:
1. Mrs. Nidora Bayola (witness to the loan agreement)
2. Mrs. Jose Magtoto (witness to the loan agreement)
3. Mr. Jimmy Saints (Messenger)
4. Notary Public

E. Document
1. Loan Agreement dated 6 March 2019
2. Promissory Note dated 6 March 2019
3. Demand Letters dated 9 June 2019; 6 July 2019; 6 August 2019

F. AVAILMENT OF MODES OF DISCOVERY

Plaintiff reserves the right to avail of the modes of discovery.

G. APPLICABLE LAWS AND JURISPRUDENCE

The Plaintiff grounds its claim on the provisions of the New Civil Code and
1997

PRAYER
WHEREFORE, the plaintiff prays that:
1. This court takes note of this pre-trial brief; and
2. Other reliefs just and equitable are likewise prayed for

September 9, 2020 Pasig City.

 ATTY. LINCOLN VELASQUEZ
Counsel for Plaintiff
Velasquez and Cortez Law Office
902, Philippine Stock Exchange, Pasig City
PTR No. 012345; 01-29-2018; Pasig City
IBP No. 441657; 01-29-2018; Pasig City
Roll of Attorney’s No. 188972
MCLE Compliance No. 6-00099092
Mobile No. 09172282228
Email: cong_velasquez@VCLaw.com

Copy Furnished:

Regional Trial Court

Branch 55
Pasig City

Atty. William Dasovich

Counsel for the Defendant
Dasovich Law Office
Makati City

EXPLANATION

            Copies of this Pre-Trial Brief was personally served by the law office
messenger to the counsel of the defendant in their law office located at # 22
H.V Dela Costa St., Makati City.

Lincoln Velasquez