Republic of the Philippines

REGIONAL TRIAL COURT

4th Judicial Region
Branch 73
Antipolo City, Rizal

DAENERYS TARGARYEN, HEIR OF

AERYS TARGARYEN III,

CIVIL CASE NO. C-785

Plaintiff,
For:
-versus-

Declaratory

Relief

for

Quieting of Title and/or to

Remove Cloud Being Cast

HEIRS OF ROBBERT BARATHEON

Upon

the

Ownership

of

NAMELY: CERSEI LANNISTER AND

Residential Lot and House

TOMMEN BARATHEON,

and Damages

Defendants.
x-------------------------------------------------------------/
PRE-TRIAL BRIEF
(for the defendant)

PRE-TRIAL BRIEF
(for the defendants)

DEFENDANTS , through counsel, unto this Honorable Court, most

respectfully submit the instant pre-trial brief and hereby avers, thus:

BRIEF STATEMENT OF CLAIMS.

The 500,000 square meter property in question, located in Sitio Kaladkad,
Barangay Inarawan, Antipolo City, was inherited by defendants from Robert
Baratheon when he died intestate in 2008. Said property was formerly owned by
Aerys Targaryen III but had sold it to Robert Baratheon in 2003 for One Million
Pesos (Php 1,000,000.00) which was bought through a loan from the Iron Banks.
In 2004, defendants successor in interest began constructing the Red
Keep, a three-storey commercial and residential building in a 400 square meter
portion of the property which was right along the newly constructed road. The

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building was finished in 2005 and was leased to tenants shortly thereafter. Total
costs for the construction was pegged at Four Million Pesos (Php 4,000,000.00).
In 2008, after the death of Robert Baratheon, defendants inherited the
property intestate and managed the property since then.
In 2010, a certain Daenerys Targaryen arrived at the property and claimed
to be its rightful owner. She sent letters demanding defendants to surrender the
property and vacate its premises. She also presented Original Certificate of Title
No. 123456 and claimed that the Transfer Certificate of Title No. 987654 under
Robert Baratheons name was invalid.
Defendants aver the veracity of TCT 987654 and the truthfulness of the
Deed of Sale which was the basis of the transfer of the property in the name of
Robert Baratheon.
Defendants also aver that they are not liable to pay any damages to
plaintiff since they acquired the property honestly and in good faith, relying on the
documents left to them by their successor-in-interest.
AMICABLE SETTLEMENT OR ALTERNATIVE MODES OF DISPUTE
RESOLUTION
Defendants are willing to enter into an amicable settlement; Likewise, if
applicable, Defendants are willing to submit the case to any of the alternative
modes of dispute resolution;
STATEMENT OF ISSUES
Defendants hereby submits the following issue/s for trial and subsequent
resolution of this Honorable Court, viz:
a. Whether or not plaintiff has legal or equitable title to the property in
question based on OCT No. 123456;
b. Whether or not the Defendant is liable to pay actual damages, rental
arrears, litigation costs, and attorneys fees.
WITNESSES
The witnesses to be presented by the petitioners are as follows, viz:
a. PETYR BAELISH - Tenant of the Red Keep, to testify that Defendants
are the heirs of Robert Baratheon;
b. TYWYN LANNISTER - Manager of the Iron Banks, to testify that the
said property was bought for One Million Pesos (Php 1,000,000.00)
through a loan;
c. ATTY. JOHN ARRYN - The lawyer of Robert Baratheon who facilitated
the sale of the property from Aerys Targaryen III and the transfer of the
title to the name of the former, to testify on the truthfulness of the
documents which are being alleged by plaintiff to have been fraudulently
acquired.
DOCUMENTARY EXHIBITS

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a. Marriage Certificate of Defendant Cersei Lannister with Roberth

Baratheon;
b. Birth Certificate of Defendant Tommen Baratheon;
c. Death Certificate of Robert Baratheon;
d. Deed of Sale of Lot No. 258963 located in Sitio Kaladkad, Barangay
Inarawan, Antipolo City;
e. Transfer Certificate Title no. 987654;
APPLICABLE LAWS AND JURISPRUDENCE
a. The pertinent provisions of the Civil Code of the Philippines, particularly,
Articles 433[1], 434[2], and 477[3].
b. And other related procedural and substantive laws.
AVAILABLE TRIAL DATES
The undersigned counsel shall make themselves available on the trial
dates agreed by the parties for complete presentation of evidence which must be
within a period from the first day of trial.
SUBMISSION OF JUDICIAL PLEADINGS
Herein defendants would like to submit judicial pleadings which shall
constitute the direct testimony of defendants witnesses subject to the crossexamination by respondents or their counsel in order to facilitate the early
disposition of the instant case.
[1] Art. 433, Civil Code of the Philippines: Actual Possession under claim of ownership raises a
disputable presumption of ownership. The true owner must resort to judicial process for the recovery of the
property.
[2] Art. 434, ibid.: In an action to recover, the property must be identified, and the plaintiff must rely on the
strength of his title and not on the weakness of the defendants claim.
[3] Art. 477, ibid.: The plaintiff must have legal or equitable title there to, or interest in the real property
which is the subject-matter of the action. He need not be in possession of said property.

RESERVATION OF TESTIMONIAL AND DOCUMENTARY EVIDENCE

Defendants 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.
MOST RESPECTFULLY SUBMITTED.
14 May 2016, Antipolo City, Rizal, Philippines.

ATTY. KEVAN LANNISTER

Counsel for Defendant
LANNISTER, LANNISTER and LANNISTER LAW OFFICE
Unit 104, Ground Floor, Rikland Centre, Marcos Highway,
Mayamot, Antipolo, 1870 Rizal
Attorneys Roll No. 643258
MCLE Compliance No. V-453458 / 07-22-2014
PTR No. 456321 / 031699 / City of Antipolo;

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IBP OR No. 147852 / 032499 / Rizal Chapter

Copy furnished:
Atty. Jorah Mormont
Counsel for Plaintiff
Unit A, 172 M.L. Quezon Street,
Barangay San Roque,
Antipolo City, Rizal
Daenerys Targaryen
#300, Pyramid St., Meereen Village,
Barangay Malanday, Marikina City
Cersei Lannister
#128, Casterly Rock St.,
Westerlands Subdivision,
Barangay Mayamot, Antipolo City
Tommen Baratheon
#128, Casterly Rock St.,
Westerlands Subdivision,
Barangay Mayamot, Antipolo City

EXPLANATION
A copy of the instant Pre-Trial Brief was registered mail and personally
served on the counsel for Plaintiff Daenerys Targaryen.

ATTY. KEVAN LANNISTER

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