TRIAL BRIEF _____ vs. _________ Case No.

RTC_________

I. BRIEF STATEMENT OF THE CASE (Here make a brief but concise summary of the fundamental facts of the case, preferably in chronological order.) II. PLEADINGS a. COMPLAINT (Here make a brief digest of each paragraph of the Complaint, indicating those that are admitted and those that are denied.) b. ANSWER ( Here make a brief digest of the Answer, including the affirmative defenses, if any.) c. COUNTERCLAIM (Follow the same procedure as in Complaint) d. ANSWER TO COUNTERCLAIM (Follow the same procedure as in Answer) e. (Follow the same procedure if there is any Crossclaim, Third-Party Complaint or Complaint if Intervention, and answers thereto.) III. MAIN ISSUES a. Legal 1. 2. 3. b. Factual 1. 2. 3. IV. EVIDENCE a. Fact No. 1 (State briefly) 1. Documentary

Exhibit A (State briefly the nature of the exhibit, and the manner of identifying the same, rendering it admissible in evidence) Exhibit B (Idem.) 2. Oral Witness A.B. (State briefly his personal circumstances and the gist of his testimony) Witness C.D (Idem.) b. Fact No. 2 (Follow the same procedure as in Fact No. 1) V. EVIDENCE, ORDER OF PRESENTATION A. STIPULATION OF FACTS (Here state briefly the facts which you believe can be stipulated with the adverse party) B. WITNESSES (Here enumerate the witnesses to be presented, in logical order, with a brief digest of their testimony, including the documentary evidence which they are to identify) C. LIST OF EXHIBITS (Here list the exhibits to be presented, with their corresponding numbers or letters. While unexpected exhibits might come up in the course of the trial, it is always advisable to list the exhibits on hand before hearing.) VI. PROBABLE EVIDENCE OF ADVERSE PARTY (Here enumerate the probable evidence which the adverse party may present, and your line of rebuttal or cross-examination.) VII. LAW AND JURISPRUDENCE

(Here copy or indicate the laws, treaties, decisions and other authorities supporting your stand)

Notes: Trial brief is not required by any rule, but it is always advisable to have one for every trial, especially in voluminous and intricate case. While there is no standard form of trial briefs, the above form is presented as a guide to lawyers. This form may be condensed or elaborated upon according to the nature of each particular case and the inclination of each individual lawyer. Modern Phil. Legal Forms, Tanada and Rodrigo