REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
BRANCH IX, BALAYAN, BATANGAS

LORENZO A. MANALO and

BENITA M. AVENAN,
Plaintiffs,

- versus - CIVIL CASE NO. 5328

ANASTACIA M. NOCHE
Defendant.
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PRE-TRIAL BRIEF
(For the Plaintiffs)

Plaintiffs through the undersigned counsel, and unto this

Honorable Court most respectfully submit the following pre-trial brief,
to wit:

I. POSSIBILITY OF AMICABLE SETTLEMENT

Plaintiffs are willing in an amicable settlement of facts which

are fair and just under circumstances;

II. SUMMARY OF ADMITTED FACTS

Plaintiffs admission are confined or limited to the admission

made in the complaint.

III. PROPOSED STIPULATIONS

Plaintiffs will offer their proposed stipulation at the pre-trial

conference of the case.

IV. I S S U E S:

1. Whether or not the plaintiffs have causes of action

against the defendant.

2. Whether or not the defendant is liable to give the plaintiffs

their shares from the produce of parcels of land owned by
their parents and from the money left by their father;

V. WITNESSES TO BE PRESENTED:
 1. The plaintiffs to prove their rights over the properties
inherited from their parents and to prove further that there was
a due influence exercise by the defendant in inheriting the
money left by their father;

2. The representative from the PNB Balayan Branch,

Balayan, Batangas to bring to the Honorable Court the
statement of account of the defendant;

3. The representative from PVAO, Batangas City to submit

to the Honorable Court the statement of monthly pension
received by their father, Marcelo Manalo from 2011 to 2013;

Respectfully submitted.

Balayan, Batangas, November 25, 2016

PUBLIC ATTORNEYS OFFICE

Department of Justice
BALAYAN, BATANGAS DISTRICT
OFFICE
Balayan, Batangas
Counsel for the Plaintiff

BY:

REMEDIOS M. BEREA
District Public Attorney

Copy furnished:

Atty. Efren R. Chavez

Balayan, Batangas