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Republic of the Philippines

REGIONAL TRIAL COURT


9th Judicial Region
Branch 29
San Miguel, Zamboanga del Sur
-o0o-

HEIRS OF TEMOTEO ALVARADO, namely; CIVIL CASE NO. 11-021


BENJAMIN ALVARADO, VICTORIA ALVARADO
ALFREDO ALVARADO, EULALIA ALVARADO
JEREMIAS ALVARADO, ARCILE ALVARADO
QUINCIANO ALVARAD and HELEN ALVARADO
Represented by GENERE ALVARADO LAMBAN
Plaintiffs,

-versus- -for-

HEIRS OF ELEUTERIO CAETE, namely; RECONVEYANCE,


GERMOHENIA CAETE, ELEUTERIO CANCELLATION OF TITLE
CAETE JR., MERCY CAETE, BEBE WITH DAMAGES
CAETE and LINDA CAETE,
Defendants,
x---------------------------------------------------------/

DEFENDANTS PRE TRIAL BRIEF

COMES NOW, defendants, through the undersigned counsel and unto


this Honorable Court, most respectfully submit their pre-trial brief, to wit;

PROPOSED STIPULATION OF FACTS:

1. Defendants through their father, Eleuterio Caete, are owners of Lot


no. 288-A, Cad-09-001737-D, covered by OCT no. T-33, 991.

2. Defendants are in possession of the above-mentioned parcel of land for


more than 30 years;

3. Defendants have been paying Real Property Taxes with respect to the
subject land.

SETTLEMENT:

Defendants are willing to enter into amicable settlement under the terms
and conditions agreeable to both parties.

DOCUMENTS/EXHIBITS:

Exhibit 1 - OCT no. T-33,991


Exhibit 2 - Real Property Tax Receipt No. 8450367
Exhibit 3 - Real Property Tax Receipt No. 8450389
Exhibit 4 - Real Property Tax Receipt No. 4594546
Exhibit 5 - Real Property Tax Receipt No. 0961161
Exhibit 6 - Real Property Tax Receipt No. 0961196
Exhibit 7 - Real Property Tax Receipt No. 4170190
Exhibit 8 - Real Property Tax Receipt No. 0038335
Exhibit 9 - Real Property Tax Receipt No. 0071868
Exhibit 10 - Real Property Tax Receipt No. 0018
Exhibit 11 - Real Property Tax Receipt No. 0075562
Exhibit 12 - Real Property Tax Receipt No. 0168970
Exhibit 13 - Real Property Tax Receipt No. 0169707
Exhibit 14 - Real Property Tax Receipt No. 0334125
Exhibit 15 - Real Property Tax Receipt No. 0335214
Exhibit 15 - Declaration of Real Property no. 2625

WITNESSES:

The defendants themselves.

ISSUES TO BE RESOLVED:

1. Whether or not defendants are in actual possession of the lot subject of


this case.

2. Whether or not plaintiffs are liable to defendants moral and exemplary


damages and Attorneys fees as prayed for in the answer.

Defendants hereby respectfully submit their pre trial brief.

Pagadian City, Philippines. January 17, 2012.

CERILLES and Associates Law Office


Counsel of the defendants
Suite No. 1, Arcada de Cerilles
B. Aquino Street, Pagadian City
By:

Atty. LEE OLIVER U. GEROMO


Roll of Attorney No. 53424
IBP No. 736574: 1/10/11
PTR No. 1855182: 1/10/11
PAGADIAN CITY

Copy furnished:
Rey C. Torrecampo
Counsel for the Palintiffs
Public Attorneys Office
Pagadian City