REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
PASIG CITY, BRANCH ___
FRA ALEJANDRO,
Plaintiff
CIVIL CASE NO.
-versus-

FOR: COLLECTION OF SUM OF

MONEY

JASMIN MICAH JABAL,

Defendant
x--------------------------------------x

C O M PLAI N T

PLAINTIFF, through counsel respectfully submits their Pre-Trial Brief, to

wit:
I
Brief Statement of Plaintiffs Claims
1, - On May 20, 2013, defendant wife Janeth N. Palautang,
executed a promissory Note, with the conformity of defendant
husband, Vong R. Palautang, In favor of the herein Plaintiff, in the
amount of ONE HUNDRED THOUSAND (P100, 000.00) PESOS,
Philippine currency, with a monthly interest of two percent (2%)
payable in ten equal monthly installments at P10, 200.00 per month
for ten (10) months beginning June 20, 2013 until March 20, 2014;

2. - Since the receipt of the amount of P100, 000.00 and from

the execution of the Promissory Note, Defendants failed to pay their
monthly installations;
3. - The outstanding account of Defendants with Plaintiff as of
the filing of this complaint is P102, 400.00;
4. - On May 21, 2014, Plaintiff, thus counsel, demanded for the
payment of Defendants account;
5. - Plaintiff did not receive any response from the Defendants,
and worse still, Defendants miserably failed to comply with their
obligation to the Plaintiff;
-26. - Plaintiff was constrained to refer the matter to the Office of
the Barangay Captain of Dumlog, Talisay City. Due to the hawkish
attitude of the Defendants, the parties failed to settle the case
amicably. The Office Dumlog was prompted to issue the Certification
to File Action;
7. - Defendants collective acts are tantamount to an assault of
the rights of Plaintiff, apart from being an outrageous attack against
the established order of society, which has resulted to the unlawful
disposition and deprivation of Plaintiffs rights. It is therefore,
imperative that moral and exemplary damages be imposed on the
Defendants for the pain and anguish which Plaintiff has felt and to
serve as a notice and warning to all parties who may have the same or
similar mental attitude as the Defendants that our Court will never
tolerate any attempt to trifle with the rights of others as such amount
the Court would assess, but which should not be less than P50,
000.00;

8. - In order to protect his right in filing this case, Plaintiff was

constrained to engage the services of counsel for an agreed fee of P30,
000.00;
9. - In protecting their interest, Plaintiff had incurred litigation
expenses in the amount of P10, 000.00 for the present.

-3IV
Documents intended to be Presented
Plaintiff reserves his right to present and mark his documentary
exhibits in the course of the proceedings of this case.
V
Admissions
Plaintiff limits his admissions to those alleged in his Complaint.
VI
Applicable Laws and Jurisprudence
Plaintiff reserves his right to submit the appropriate memorandum
citing the laws and jurisprudence applicable to this case
VII
Issues:
1, - Whether or not Plaintiff have causes of action against the
Defendants;

2, - Whether or not Plaintiff is entitled to any and all damages

contemplated in his Complaint.
RESPECTFULLY SUBMITTED UPON RECEIPT.
Cebu City (for Talisay City, Cebu), Philippines, August 26, 2014
MARISTELA A. REGIDOR
Counsel of the Plaintiff
Rm. 100 USJR Bldg.
Magellans St., Cebu
City
IBP OR No. 950196
1/10/14 Cebu Prov.
PTR no. 4625678 3/3/14 Cebu City
Roll No. 98765 April,
2012
MCLE no. IV-001234
Tel No. 253-7017; Cell
No. 0932-305-1218
Copy furnished:
Atty. Lucks Mae Digaum & Atty. Venice Santisteban
Counsel of the Defendants
DIGAUM DORMASO PERIDA & SANTISTEBAN LAW
Rm 222, Washington Plaza Bldg,
Freedom Park St., Cebu City