CHRISTELLE DIVINAGRACIA

JD 3B

Republic of the Philippines

Region VI
Regional Trial Court Iloilo City
Branch 32

JOLINA RIZON
Plaintiff,
Case No. 1162333
For: Sum of Money

- versus –

MARICEL CARLOS,
Defendant.
X------------------------------X

Pre-Trial Brief
(Plaintiff)

PLAINTIFF, through counsel and unto this Honorable Court, most respectfully submit the
instant Pre-trial brief and hereby avers, states:

BRIEF STATEMENT OF CLAIMS

1. Defendant borrowed P800,000.00 from the Plaintiff. With this, Defendant executed a
Promissory Note, which stated that the Defendant pro mises to pay Plaintiff on January
15, 2019 with 15% interest per annum, signed on January 15, 2018.
2. Plaintiff waited for the Defendant’s payment on the date due stated in the Promissory
Note, however, no payment was made.
3. With this, Plaintiff personally sent a demand letter on January 20, 2019, reminding the
Defendant of what was due. Furthermore, it is stated in the letter that Defendant has
within five (5) days from the receip t of the letter to pay.
4. Defendant received the letter via LBC on January 21, 2019, but did not pay. With this,
Plaintiff asked the counsel to send a final dem and letter dated January 30, 2019, which
once again reminded Defendant of what was due and once again Defendant was given
within five (5) days from the receipt of the letter to pay, otherwise Plaintiff will take legal
action.
5. Defendant received the final demand letter via LBC on January 31, 2019, however, she
did not pay.
CHRISTELLE DIVINAGRACIA
JD 3B

AMICABLE SETTLEMENT OR ALTERNATIVE MODES OF DISPUTE RESOLUTION

PLAINTIFF is willing to enter into an an amicable settlement; likewise, if applicable,
PLAINTIFF is willing to submit the case to any of the alternative modes of dispute
resolution.

STATEMENTS OF ISSUE
PLAINTIFF hereby submits the issue for trial and subsequent resolution for this
Honorable Court, viz: Whether or not the defendant’s obligation is declared in default and
must be due and demandable.

WITNESSES

The witnesses to be presented by the plaintiff are as follows:

1. JOLINA RIZON, The Plaintiff herself, to testify regarding the Defendant who did
not pay the amount borrowed from Plaintiff.
2. ALBERTO RIZON, one of the witnesses who signed in the promissory note.
3. RAINA ALEJER, one of the witnesses who signed in the promissory note.

DOCUMENTARY EXHIBITS
1. Promissory Note
2. Acknowledgement Receipts
3. Demand letter

AVAILABLE TRIAL DATES

The undersigned counsel shall make themselves available on the trial dates
agreed upon by the parties for complete presentation of evidence which must be within a
specified period from the first day of trial.

SUBMISSION OF JUDICIAL PLEADINGS

Herein PLAINTIFF would like to submit judicial pleadings which shall constitute the
direct testimony of PLAINTIFF’s witnesses subject to th ecross-examination by
defendants or their counsel in order to facilitate theearly disposition of the instant case.

RESERVATION OF TESTIMONIAL AND DOCUMENTARY EVIDENCE

PLAINTIFF hereby reserve the right to present additional testimonial and/or
documentary evidence in the course of the trial as they may deem fit and necessary
towards the successful litigation of their causes of action.
CHRISTELLE DIVINAGRACIA
JD 3B

MOST RESPECTFULLY SUBMITTED.

30 September 2019, Iloilo City, Philippines

ATTY. CHRISTELLE G. DIVINAGRACIA

Counsel of the Petitioner
Until December 31, 2023
11th Floor,
JMB Building
Ungka II, Iloilo City
Attorney’s Roll No. 97112; 06.06.18
IBP No. 032118; 07.18.2018; Iloilo City
PTR No. 3875421; 07.18.2018; Iloilo City
MCLE Compliance No. IV-0000987; 07.27.2018
Tel. No. (033) 303-3716
Cell Phone No. 09452941213
Email Address: CGD@AceLawFirm.ph

Copy furnished:

By Personal Service

LOUIE PEREZ
Counsel for Defendants
Roll of Attorney No. 56567
IBP O.R. No. 654321 (11/20/15)
PTR O.R. No. 0134876(10/10/14)
Ground Floor ALS Bldg.
Ortiz St., IloiloCity
Telephone No. (033) 866-3716
E-mail address thefirm@PerezLawFirm.ph

MARICEL CARLOS
Mandurriao, Iloilo City