Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 67
Pasig City

huhuhuhuhu,
Plaintiff,

-versus- Civil Case No. 1111

jajajaja.,
Defendants.
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PRE-TRIAL BRIEF

Defendant, jajajaja, by counsel, unto the Honorable Court, most

respectfully states:

AS TO THE POSSIBILITY OF ENTERING

INTO A COMPROMISE AGREEMENT
OR AMICABLE SETTLEMENT

Defendant is willing to discuss any reasonable proposal that may lead to

an amicable settlement.

STATEMENT OF THE CLAIM OF THE DEFENDANT

 Defendant is resisting the action on the ground that the plaintiff has no

right that may be asserted to the subject property by succession or otherwise.

That she is interposing a counter-claim as the action filed by the plaintiff is

without basis in fact and in law.

PROPOSALS FOR STIPULATION

Defendant proposes the following stipulations:

1. That defendant is the daughter of the late Eusebio Salandanan who

is a brother of Maria Salandanan Tiangco.

2. That the late Anastacio Salandan executed a Deed of Donation in

favor of the defendant on April 26, 1990.

3. That plaintiff has received that real property embraced in TCT No. T-

97347 from his adoptive parents.

3.1 That this property can be considered his advance legitime.

 4. That plaintiff has not resided in the subject property since 1990.

That defendant is willing to enter into other stipulations during the pre-trial

conference.

ISSUES TO BE LITIGATED

The defendant submits that the issues are:

1. Whether or not, the plaintiff has a right to the subject property?

2. Whether or not, the plaintiff is liable for defendant’s counter-claim?

DOCUMENTARY EVIDENCES

The defendant intends to present the following:

1. Deed of Donation dated April 26, 1990.

2. Affidavit of Self-Adjudication dated November 10, 1997.

 That defendant reserve the right to present other documentary evidences

as may be appropriate to establish her claims or rebut that of the plaintiff.

WITNESSES

The defendant will testify in her behalf. She also intends to present

corroborating witnesses.

TRIAL DATES

Defendant will require five (5) trial dates which may be fixed upon

consultation with the calendar of the Court.

Baguio City for Pasig City, this 12th day of September, 2012.

THE LAW hyuhduhasishdias

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