5 891776824311283718

Republic of the Philippines
Third Judicial Region

First Municipal Circuit Trial Court
Dinalupihan-Hermosa
Province of Bataan
Spouses Carlito V. Sapno and Rosario

Q. Sapno,
Plaintiffs,
- versus - Case No. 1584

For: Ejectment and Damages
Rowena P. Ganaden and Jerry R.

Ganaden, Joined by their
respective spouses,
Defendants.
X---- --------------------------------------- -----------X
Pre-Trial Conference Brief

for the Plaintiffs
Come Now Plaintiffs, thru and by the undersigned counsel, unto this
Honorable Court, most respectfully submit this Pre-Trial Conference Brief and
accordingly state as follows:
A. A statement of their willingness to enter into amicable settlement or

alternative modes of dispute resolution, indicating the desired terms
thereof insofar as allowed by law.
Plaintiffs are willing to enter into reasonable amicable

settlement of the instant case with the defendants insofar as
allowed by law.
B. Summary of admitted facts and proposed stipulations of facts:
 Plaintiffs entered into a contract to sell with the

Philippine National Bank (PNB) to purchase two parcels
of land located at Happy Valley, Dinalupihan, Bataan
which are particularly described as Lot 8, measuring
256 square meters, more or less, covered by TCT No. T-
119723, and Lot 9, measuring 240 square meters, more
or less, covered by TCT No. T-119649;
 Said properties are still declared for tax purposes under
the name of PNB as per Tax Declaration Nos. 06096
and 06097;
 Realty taxes due the subject properties have been
religiously paid until the year 2016, as evidenced by
Official Receipt No. 0346920;
 The defendants are the ones presently occupying the
subject properties;
 Defendants were asked by PNB to vacate the property
by sending them the appropriate notice to vacate on
June 02, 2015;
 The PNB authorized the Plaintiffs to be responsible in
the ejectment of occupants at their own expense;
 Defendants had been occupying the subject properties
without any legal right to do so;
 This case had undergone the appropriate Barangay
conciliation proceedings but no settlement was
reached;
 A demand letter dated January 05, 2016 was sent to
the defendants; thereby giving them five (5) days from
receipt thereof within which to vacate the said
properties;
 Despite receipt of the demand letters on January 07,
2016, however, defendants still refused to vacate;
 To date, defendants have not yet vacated the subject
properties;
B. The issues to be resolved:
 Who has better right of possession on the subject property;

 Whether or not the defendants and all persons claiming rights
over the subject property should be ordered to vacate the
same and to restore possession thereof to the plaintiffs;
 Whether or not defendants are liable to pay damages for their
wrongful, deliberate, and malicious act;
 Whether or not defendants are liable to pay the amount of
attorney’s fees which the plaintiffs incurred for the protection
of their rights in court.
C. Documents to be presented by the plaintiffs:

A. PNB leaflet
B. TCT No. T-119723
C. TCT No. T-119649
D. subdivision plan showing the location of the subject parcels of
land
E. Notice to Vacate by PNB dated June 01, 2015
F. Letter by PNB dated July 3, 2015
G. Contract to Sell dated August, 2015
H. Tax Declaration No. 06096
I. Tax Declaration No.06097
J. Official Receipt No. 0346920
K. and series Minutes of the meetings with the Barangay
L. Certificate to File Action dated January 4, 2016
M. and series Demand Letter dated January 05, 2016 and the
corresponding return cards
Plaintiff reserves the right to mark other documents during trial.
D. The number and names of the witnesses, the substance of their

testimonies, and the approximate number of hours that will be
required by the parties for the presentation of their respective
witnesses.
The names and address of the witnesses as well as the

substance of their testimony will be supplied at the actual pre-trial
conference proper, with all due respect.
Respectfully submitted.
Dinalupihan, Bataan, August 04, 2016.
Roniel D. Muñoz
Counsels for the Plaintiffs
Sanchez-Malit Building
Sta. Isabel, Dinalupihan, Bataan
Roll of Attorney No. 63074
IBP No. 924131, 01/06/2016
PTR No. 3058381, 01/06/2016
MCLE Compliance No. V-0018535
Copy furnished:
Public Attorney’s Office

Dinalupihan, Bataan
Regional Trial Court
Branch 5
Dinalupihan, Bataan
Spouses Fermin Langit and

Merlyn M. Langit
Plaintiffs,
- versus - Civil Case No. DH-1416-15

For: Abatement of Nuisance/
Just Compensation Plus
Damages
National Irrigation
Administration,
Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x

for the Plaintiffs
Come Now Plaintiffs, thru and by the undersigned counsels, unto this


allowed by law.
 Plaintiffs are the owners of a parcel of rice land,

located at Luacan, Dinalupihan, Bataan, measuring
Twenty Thousand Four Hundred Thirty one (20, 431)
square meters, more or less, and covered by Transfer
Certificate of Title No. 038-2014008051 issued by the
Registry of Deeds for the Province of Bataan;
 The subject property is declared for tax purposes under
the name of the plaintiffs as evidenced by Tax
Declaration No. 30842;
 The real property taxes due are religiously paid by the
plaintiffs as evidenced by the Official Receipt No.
0327942;
 The subject property was previously owned by one
Beatriz V. Saplala as evidenced by Transfer Certificate
of Title No. CLOA-331 and Tax Declaration no. 07497;
 On August 03, 1995, plaintiffs bought the subject
property from Beatriz Saplala as evidenced by their
Deed of Absolute Sale of Real Property
 The subject property is a pure rice land without any
construction/infrastructure built therein at the time
the plaintiffs bought it;
 Defendant constructed a concrete canal without the
knowledge and consent of the plaintiffs, and without
instituting expropriation proceedings or even
indemnifying plaintiffs;
 The construction was left unfinished and abandoned by
the defendant and the unfinished portion lies right in
the middle of plaintiffs’ property;
 Because the unfinished portion lies in the middle of the
plaintiffs’ property, the whole property of the Plaintiffs
is adversely affected;
 Plaintiffs were prevented from planting palay since
1997 because of the situation of the subject property;
 The subject property would yield more or less 150
cavans of rice every year, or more or less one hundred
fifty thousand pesos (Php 120, 000.00);
 Plaintiffs made several verbal and written demands
from defendant requesting it to take action and
remove the said canal but no action was taken;
 Despite the aforementioned letters, demands and
efforts to settle on the part of the plaintiffs, defendant
ignored and continues to ignore its clear liability to the
former;
C. The issues to be resolved:
 Whether the Plaintiffs are entitled to the relief sought in their

complaint;
 Whether defendants are liable to pay the amount of attorney’s
fees which the plaintiffs incurred for the protection of their
rights in court.
D. Documents to be presented:
N. Transfer Certificate of Title No. 038-2014008051

O. Tax Declaration No. 30842
P. Official Receipt No. 0327942
Q. Transfer Certificate of Title No. CLOA-331
R. Tax Declaration no. 07497
S. Deed of Absolute Sale of Real Property dated August 03, 1995
T. and series Pictures showing the said unfinished concrete canal
U. Demand Letter dated September 06, 2013
V. and series Demand Letter dated May 09, 2014 and corresponding
receipt by the defendant
W. and series Demand Letter dated May 07, 2015 and corresponding
receipt by the defendant
E. The number and names of the witnesses, the substance of their

witnesses.

conference proper, with due respect.

By:
Juvy Mell B. Sanchez-Malit

IBP No. 924130, 01/06/2016
PTR No. 3058380, 01/06/2016
Roniel D. Muñoz
IBP No. 924131, 01/06/2016
PTR No. 3058381, 01/06/2016
Copy furnished:
Legal Services Department

National Irrigation Administration
Counsel for the Respondent
G/F NIA Building A
EDSA, Diliman, Quezon City
Explanation:
The above pleading will be served to the opposing counsels by

registered mail due to the distance involved and lack of staff to cause
personal service as permitted under the rules.

Dinalupihan-Hermosa
Province of Bataan
Gregorio I. Cudia, represented by

Almario M. Cudia, Sr.,
Plaintiff,

Juliet Cahilig, Et. Al.,

Defendants.
X---- --------------------------------------- -----------X

for the Plaintiff
Comes Now Plaintiff, thru and by the undersigned counsel, unto this
Honorable Court, most respectfully submits this Pre-Trial Conference Brief
and accordingly states as follows:
E. A statement of their willingness to enter into amicable settlement or

Plaintiff is willing to enter into reasonable amicable

allowed by law.
F. Summary of admitted facts and proposed stipulations of facts:
 Plaintiff is represented herein by his attorney-in-fact,

Almario M. Cudia Sr., by virtue of a Special Power of
Attorney executed on March 02, 2015;
 Plaintiff is the absolute and registered owner of a
property located at Naparing, Dinalupihan, Bataan,
measuring One thousand three hundred fifty five (1,
355) square meters, more or less, covered by Transfer
Certificate of Title No. T-70394 issued by the Registry of
Deeds for the Province of Bataan on August 03, 1977;
 Said property is declared for tax purposes under the
name of the plaintiff as per Tax Declaration No. 07909;
 Realty taxes due the subject property have been
religiously paid by the plaintiff until the year 2015, as
evidenced by Official Receipt No. 0286533;
 Defendants have been occupying the property for a
long time now but only by mere tolerance of the
plaintiff;
 Sometime in the early part of 2015, plaintiff talked to
the defendants for the latter to vacate the subject
property. Defendants, nevertheless, refused to vacate
the said property;
 Demand letters dated February 04, 2015 were sent to
the defendants; thereby giving them fifteen (15) days
from receipt thereof within which to vacate the said
property;
 Despite receipt of the demand letters on March 26,
2015, however, defendants still refused to vacate;
 The matter was brought to the Office of Barangay
Naparing, Dinalupihan, Bataan but the parties were not
able to settle the issue.;
property;
G. The issues to be resolved:
 Whether or not the Plaintiff is entitled to the possession of the

subject property;
same and to restore possession thereof to the plaintiff;
attorney’s fees which the plaintiff incurred for the protection
of its rights in court.
H. Documents to be presented by the plaintiff:
X. Special Power of Attorney executed on March 02, 2015

Y. Transfer Certificate of Title No. T-70394
Z. Tax Declaration No. 07909
AA. Official Receipt No. 0286533
BB. Demand Letters dated February 04, 2015
CC. Return Cards
DD. Certification to File Action was issued by the Office of Barangay
Naparing, Dinalupihan, Bataan on March 27, 2015
I. The number and names of the witnesses, the substance of their

witnesses.

Roniel D. Muñoz
Counsel for the Plaintiff
Roll No. 63074
PTR No. 3058381, 01/06/2016
IBP No. 924131, 01/06/2016
Copy furnished:
Atty. Juliano P. Nacino

Nacino Venida and Associates
Unit 404, Metroview SVN Building
Pres. Quirino Ave., corner San Antonio St.,
Malate, Manila
Supreme Court
Branch 5
Dinalupihan, Bataan
Joel M. Danan,
Petitioner,
- versus – Civil Case No. DH-1365-14

For: Declaration of Nullity of Marriage
Lericar F. Gorospe,
Respondent.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Petitioner
Comes Now Petitioner, thru and by the undersigned counsels, and to
this Honorable Board, most respectfully submits this Pre-Trial Brief and
accordingly states as follows:
J. A statement of their willingness to enter into amicable settlement or

Not allowed in annulment of marriage cases.
K. Summary of admitted facts and proposed stipulations of facts:
Proposed Stipulation of facts:
 Fact of marriage: Parties got married on December 23, 1992 in

Olongapo City as per their Marriage Contract;
 Fact of birth of parties’ child: Parties have one child, Eric Joel
Gorospe Danan who was born on April 26, 1993, now 26 year
old;
 Parties did not acquire real properties during their consortium;
 Parties had been separated since 1995;
L. The issue to be resolved:
 Whether or not there is legal ground or there are legal grounds

to declare that the marriage of the parties herein is a nullity
based on Article 36 of the Family Code of the Philippines
M. Documents to be presented by the plaintiff:
Exhibits Documents
A Marriage Contract of the parties

B Certificate of Live Birth of their child
C Information in Crim. Case No. 280-2011-FC
D Order dated October 5, 2012 of RTC-73
Olongapo City in Crim. Case No. 280-2011-FC
E Psychological Evaluation Report
Petitioner reserves the marking of other documents in the course of the

trial.
N. The number and names of the witnesses, the substance of their
witnesses.
The petitioner will be presented as one of the witnesses to

prove the allegations contained in his Petition. He will also
present psychiatrist and other witnesses to support his allegations.
Dinalupihan, Bataan, July 28, 2016.
Counsels for the Petitioner

By:

IBP No. 924130, 01/06/2016
PTR No. 3058380, 01/06/2016
Roniel D. Muñoz
IBP No. 924131, 01/06/2016
PTR No. 3058381, 01/06/2016
Copy furnished:
Office of the Provincial Prosecutor (OPP)

Balanga City, Bataan
Explanation:
A copy of the foregoing will be served upon the OPP thru registered
mail due to lack of staff to cause personal service.

Supreme Court
Branch 5
Dinalupihan, Bataan
Irene G. Ponce-Morales,
Petitioner,
Rolando T. Morales,
Respondent.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Petitioner


a. Fact of marriage: Parties got married on October 15, 1996 in

Nasugbu, Batangas as per their Certificate of Marriage;
b. Fact of birth of parties’ children: Parties have two children; Roie
Allen born on January 30, 1997 and Rose Alain born on February 2,
2002;
c. Parties did not acquire real properties during their consortium;
d. Parties had been separated since 2011;
C. The issues to be resolved:
a. Whether or not there is legal grounds to declare that the marriage

of the parties herein is a nullity based on Article 36 of the Family
Code of the Philippines;
D. Documents to be presented by the plaintiff:
Exhibits Documents
A Certificate of Marriage
B Certificate of Live Birth of Roie Allen
B-1 Certificate of Live Birth of Rose Alain
C Psychological Evaluation Report

trial.
E. The number and names of the witnesses, the substance of their

witnesses.

prove the allegations contained in her Petition. She will also
present psychiatrist and other witnesses to support her
allegations.

By:

IBP No. 924130, 01/06/2016
PTR No. 3058380, 01/06/2016
Roniel D. Muñoz
IBP No. 924131, 01/06/2016
PTR No. 3058381, 01/06/2016
Copy furnished:

Explanation:

Supreme Court
Branch 5
Dinalupihan, Bataan
Susana Japon Giray,

Petitioner,

Wilfredo M. Giray,
Respondent.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Petitioner

C. A statement of their willingness to enter into amicable settlement or

D. Summary of admitted facts and proposed stipulations of facts:
 Fact of marriage: Parties got married on March 17, 1984 in

Zamboanguita, Negrow Occiental as per their Marriage
Contract;
 Fact of birth of parties’ children: Parties have four children; all
of whom had already attained the age of majority;
 Parties did not acquire real properties during their consortium;
 Parties had been separated since 2007;
E. The issues to be resolved:
 Whether or not there is legal ground to declare that the
marriage of the parties herein is a nullity based on Article 36 of
the Family Code of the Philippines;
F. Documents to be presented by the plaintiff:
Exhibits Documents
A Marriage Contract of the parties

B Criminal Information filed against
respondent
C Pagpapatunay by Gonzalo Antonio, Jr.
C-1 Pagpapatunay by Albert M. Diciembre
D Psychological Evaluation Report

trial.
G. The number and names of the witnesses, the substance of their

witnesses.

allegations.

By:

IBP No. 924130, 01/06/2016
PTR No. 3058380, 01/06/2016
Roniel D. Muñoz
IBP No. 924131, 01/06/2016
PTR No. 3058381, 01/06/2016
Copy furnished:

Explanation:
Supreme Court
Branch 5
Dinalupihan, Bataan
Irene G. Ponce-Morales,
Petitioner,

Rolando T. Morales,
Respondent.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Petitioner

F. A statement of their willingness to enter into amicable settlement or

G. Summary of admitted facts and proposed stipulations of facts:
a. Fact of marriage: Parties got married on October 15, 1996 in

Nasugbu, Batangas as per their Certificate of Marriage;
b. Fact of birth of parties’ children: Parties have two children; Roie
Allen born on January 30, 1997 and Rose Alain born on February 2,
2002;
c. Parties did not acquire real properties during their consortium;
d. Parties had been separated since 2011;
H. The issues to be resolved:
a. Whether or not there is legal grounds to declare that the marriage

of the parties herein is a nullity based on Article 36 of the Family
Code of the Philippines;
I. Documents to be presented by the plaintiff:
Exhibits Documents
A Certificate of Marriage
B Certificate of Live Birth of Roie Allen
B-1 Certificate of Live Birth of Rose Alain
C Psychological Evaluation Report

trial.
J. The number and names of the witnesses, the substance of their

witnesses.

allegations.

By:
IBP No. 924130, 01/06/2016
PTR No. 3058380, 01/06/2016
Roniel D. Muñoz
IBP No. 924131, 01/06/2016
PTR No. 3058381, 01/06/2016
Copy furnished:

Explanation:
Branch 5
Dinalupihan, Bataan
Marilyn E. Manuel, joined by

her husband Roberto Manuel,
Plaintiffs,

For: Revival of Judgment
Alfredo Elimansil et. al.,

Defendant.
X-------------------------------------------------------X

for the Plaintiffs
Come Now Plaintiffs, thru and by the undersigned counsels, unto this
H. A statement of their willingness to enter into amicable settlement or

allowed by law.
I. Summary of admitted facts and proposed stipulations of facts:
 Existence and due execution of the decision of the DAR

Provincial Adjudicator dated January 21, 2002 ordering
defendants, their heirs, assigns, successors-in-interest
and all persons acting for and in their behalves
claiming rights/authority under them to cease and
desist from further harassing plaintiff’s peaceful
possession, occupation and cultivation of the subject
landholding;
 Existence and due execution of the decision of the
DARAB Central Office dated December 9, 2004
affirming the decision stated above;
 To date, the decision remains to be unsatisfied because
the defendants are still occupying the subject property
despite repeated demands from the plaintiff;
J. The issues to be resolved:
 Whether the Plaintiffs are entitled to the relief sought in their

complaint;
 Whether defendants are liable to pay the amount of attorney’s
fees which the plaintiffs incurred for the protection of their
rights in court.
K. Documents to be presented:
EE.Complaint entitled Marilyn E. Manuel v. SPO4 Alfredo M.

Elimansilin, et. al., DARAB Case No. 0301-0472-01 for Forcible
Entry with Preliminary Mandatory Injunction filed in 2001
FF. Decision of the DAR Provincial Adjudicator dated January 21,
2002
GG. Decision of the DARAB Central Office dated December 9,
2004
HH. Entry of Judgment issued by the DARAB Central Office
dated May 16, 2005
II. Motion for Execution dated June 7, 2005
JJ. Order dated September 05, 2005 granting the motion.
KK. Writ of Execution dated October 04, 2005 issued in favor
of the plaintiffs
LL. and series Sheriff’s Returns dated November 18, 2005 and
December 01, 2005
MM. Motion for Special Order of Demolition dated December
14, 2005
NN. Order dated March 27, 2006 granting the motion.
OO. Writ of Demolition dated May 18, 2006 issued in favor of
the plaintiffs
PP.The document entitled “Pagsasalin ng Karapatan at Kasunduan”
dated June 15, 2011
QQ. Ex-parte Motion for Issuance of Alias Writ of Demolition
dated November 12, 2012
RR. Order dated April 14, 2013
L. The number and names of the witnesses, the substance of their

witnesses.

Dinalupihan, Bataan, June 20, 2016.

By:

IBP No. 924130, 01/06/2016
PTR No. 3058380, 01/06/2016
Roniel D. Muñoz
IBP No. 924131, 01/06/2016
PTR No. 3058381, 01/06/2016

REGIONAL TRIAL COURT
BRANCH 5
Dinalupihan, Bataan
SPS. Pablo D. Enovejas and Violeta
M. Enovejas,
Plaintiffs,
-versus- Civil Case No. DH-1442-16

For: Annulment of the
Deed Of Absolute Sale,
Reinstatement Of Title And
Damages
Amparo Gorospe, The Register of

Deeds for the Province of Bataan and
the Municipal Assessor of Hermosa,
Bataan,
Defendants.
X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - X
Pre-Trial Brief
for Defendant Amparo Gorospe
Comes Now Defendant Gorospe, thru and by the undersigned

counsels, and to this Honorable Court, most respectfully submits this Pre-Trial
Brief and accordingly states as follows:
M. A statement of her willingness to enter into amicable settlement or

Defendant Gorospe is willing to enter into any

reasonable settlement or alternative modes of dispute
resolution.
N. Summary of admitted facts and proposed stipulations of facts:
 On March 2, 2005, the parties in this case entered into

a Real Estate Mortgage (REM) for the amount of One
Hundred Thousand Pesos (Php 100,000.00);
 Existence and due execution of the REM dated March
02, 2005;
 The mortgagor, Violeta M. Enovejas, did not pay
Defendant Gorospe;
 In order to fulfill their obligation, Violeta and Pablo
instead executed a Deed of Absolute Sale of Real
Property dated January 11, 2008 over the subject
property in consideration of the Php 100,000.00 debt;
 With the execution of the Deed of sale, Defendant
Gorospe had the reasonable ground to believe that
she was already the owner of the property;
O. The issues to be resolved:
 Whether or not the plaintiffs have a valid cause of

action against the Defendant Gorospe;
 Who is the owner of the subject property;
 Whether or not Defendant Gorospe is entitled to
damages;
P. Documents to be presented by the petitioner:
1 Real Estate Mortgage dated March 02, 2005

2 Certificate Authorizing Registration (CAR)
3 Certification issued by the Office of the Provincial Assessor
4 and series Official Receipts issued by the Office of the Treasurer of
the Municipality of Hermosa, Bataan
Defendant Gorospe reserves the right to mark other

documents during trial.
Q. The number and names of the witnesses, the substance of their

witnesses.
The names and address of the witnesses as well as

the substance of their testimony will be supplied at the
actual pre-trial conference proper instead.
Dinalupihan, Bataan, May 17, 2016.
Counsels for Defendant Gorospe

By:

IBP No. 924130, 01/06/2016
PTR No. 3058380, 01/06/2016
Roniel D. Muñoz
IBP No. 924131, 01/06/2016
PTR No. 3058381, 01/06/2016
Copy furnished:
Atty. Peter Paul S. Maglalang

Maglalang Lagman & Maglalang Law Offices
#145 1st St., Dolores Homesite,
Dolores, City of San Fernando, Pampanga
Explanation:
The above pleading will be served to the opposing counsel by registered mail due
to the distance involved and lack of staff to cause personal service as permitted under the
rules.
REPUBLIC OF THE PHILIPPINES
THIRD JUDICIAL REGION
BRANCH 5
DINALUPIHAN, BATAAN
WILFREDO S. MANLULU, IRMA S.

MANLULU AND MA. ANGELITA M.
GARCIA,
Plaintiffs,
-versus- Civil Case No. DH – 1429-15

For: Recovery Of Possession
And Shares Under An Implied
Trust
SPS. RODOLFO MANLULUNU JR.,

AND JOCELYN A. MANLULU AND
CARMELA MANLULU
Defendants.
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Pre-Trial Brief
for the Defendants Rodolfo Jr. and Jocelyn Manlulu
Come Now Defendants Rodolfo Jr. and Jocelyn Manlulu, thru and by
the undersigned counsels, and to this Honorable Court, most respectfully
submit this Pre-Trial Brief and accordingly state as follows:
R. A statement of their willingness to enter into amicable settlement or

Defendants Rodolfo Jr. and Jocelyn Manlulu are

willing to enter into any amicable settlement or
alternative modes of dispute resolution.
S. Summary of admitted facts and proposed stipulations of facts:

 The properties where defendants-spouses are
occupying and conducting their business at present
were not merely inherited but were obtained by them
thru their own efforts;
 The subject property described in Annexes C and D in
the complaint is NOT THE SAME property that they
are currently occupying.;
 Existence and due execution of the Decision dated
March 3, 1997 rendered in Civil Case No. 1013,
entitled Rodolfo Manlulu, Jr., v. Wilfredo Manlulu,
filed before the First Municipal Trial Court of
Dinalupihan-Hermosa, Bataan;
T. The issues to be resolved:

action against the Defendants Manlulu;
 Whether or not Defendants Manlulu are entitled to
damages.
U. Documents to be presented by the petitioner:
5 and series Documents showing that Defendants Manlulu have a

stable source of income, contrary to what the plaintiffs are alleging
6 and series Tax Declaration Nos. 030040 and 02067
7 and series Official Receipts
8 Notice of Assessment and Tax Bill issued by the Municipality of
Dinalupihan, Bataan
9 Decision dated March 3, 1997 rendered in Civil Case No. 1013,
entitled Rodolfo Manlulu, Jr., v. Wilfredo Manlulu, filed before
the First Municipal Trial Court of Dinalupihan-Hermosa, Bataan
Defendants Rodolfo Jr. and Jocelyn Manlulu

reserve the right to mark other documents during trial.
V. The number and names of the witnesses, the substance of their

witnesses.
actual pre-trial conference proper instead.

By:

IBP No. 924130, 01/06/2016
PTR No. 3058380, 01/06/2016
Roniel D. Muñoz
IBP No. 924131, 01/06/2016
PTR No. 3058381, 01/06/2016
BRANCH 5
Dinalupihan, Bataan
SPS. Pablo D. Enovejas and Violeta

M. Enovejas,
Plaintiffs,

For: Annulment of the
Deed Of Absolute Sale,
Reinstatement Of Title And
Damages
Amparo Gorospe, The Register of

Deeds for the Province of Bataan and
the Municipal Assessor of Hermosa,
Bataan,
Defendants.
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Pre-Trial Brief
for Defendant Amparo Gorospe
Comes Now Defendant Gorospe, thru and by the undersigned

counsels, and to this Honorable Court, most respectfully submits this Pre-Trial
W. A statement of her willingness to enter into amicable settlement or

Defendant Gorospe is willing to enter into any

amicable settlement or alternative modes of dispute
resolution.
X. Summary of admitted facts and proposed stipulations of facts:
 On March 2, 2005, the parties in this case entered into

a Real Estate Mortgage (REM) for the amount of One
Hundred Thousand Pesos (Php 100,000.00);
 Existence and due execution of the REM dated March
02, 2005;
 The mortgagor, Violeta M. Enovejas, did not pay
Defendant Gorospe;
 In order to fulfill their obligation, Violeta and Pablo
instead executed a Deed of Absolute Sale of Real
Property dated January 11, 2008 over the subject
property in consideration of the Php 100,000.00 debt;
 With the execution of the Deed of sale, Defendant
Gorospe had the reasonable ground to believe that
she was already the owner of the property;
Y. The issues to be resolved:

action against the Defendant Gorospe;
 Whether or not Defendant Gorospe is entitled to
damages.
Z. Documents to be presented by the petitioner:
10 Real Estate Mortgage dated March 02, 2005

11 Certificate Authorizing Registration (CAR)
12 Certification issued by the Office of the Provincial Assessor
13 and series Official Receipts issued by the Office of the Treasurer
of the Municipality of Hermosa, Bataan
Defendant Gorospe reserves the right to mark other

AA. The number and names of the witnesses, the substance of their
witnesses.

actual pre-trial conference proper, with due respect.
Counsels for Defendant Gorospe

By:

IBP No. 924130, 01/06/2016
PTR No. 3058380, 01/06/2016
Roniel D. Muñoz
IBP No. 924131, 01/06/2016
PTR No. 3058381, 01/06/2016
REPUBLIC OF THE PHILIPPINES
THIRD JUDICIAL REGION
BRANCH 5
DINALUPIHAN, BATAAN
WILFREDO S. MANLULU, IRMA S.

MANLULU AND MA. ANGELITA M.
GARCIA,
Plaintiffs,
-versus- Civil Case No. DH – 1429-15

For: Recovery Of Possession
And Shares Under An Implied
Trust
SPS. RODOLFO MANLULUNU JR.,
AND JOCELYN A. MANLULU AND
CARMELA MANLULU
Defendants.
X- - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - -- - - - - - - - - -- - - - - - - - - - - X
Pre-Trial Brief
for the Defendants Manlulu
Come Now Defendants Manlulu, thru and by the undersigned

counsels, and to this Honorable Court, most respectfully submit this Pre-Trial
Brief and accordingly state as follows:
BB. A statement of their willingness to enter into amicable

settlement or alternative modes of dispute resolution, indicating the
desired terms thereof insofar as allowed by law.
Defendants are willing to enter into any amicable

settlement or alternative modes of dispute resolution.
CC. Summary of admitted facts and proposed stipulations of facts:
 The properties where defendants-spouses are

occupying and conducting their business at present
were not merely inherited but were obtained by them
thru their own efforts;
 The subject property described in Annexes C and D in
the complaint is NOT THE SAME property that they
are currently occupying.;
 Existence and due execution of the Decision dated
March 3, 1997 rendered in Civil Case No. 1013,
entitled Rodolfo Manlulu, Jr., v. Wilfredo Manlulu,
filed before the First Municipal Trial Court of
Dinalupihan-Hermosa, Bataan;
DD. The issues to be resolved:

action against the Defendants Manlulu;
 Whether or not Defendants Manlulu are entitled to
damages.
EE.Documents to be presented by the petitioner:
14 and series Documents showing that Defendants Manlulu have a

stable source of income, contrary to what the plaintiffs are alleging
16 and series Official Receipts
17 Notice of Assessment and Tax Bill issued by the Municipality of
Dinalupihan, Bataan
18 Decision dated March 3, 1997 rendered in Civil Case No. 1013,
entitled Rodolfo Manlulu, Jr., v. Wilfredo Manlulu, filed before
the First Municipal Trial Court of Dinalupihan-Hermosa, Bataan
Defendants Manlulu reserve the right to mark

other documents during trial.
FF. The number and names of the witnesses, the substance of their
witnesses.


Branch 5
Dinalupihan, Bataan
Teresa Gutierrez-Aspirin and

Leonardo Gutierrez,
Plaintiffs,

Teresita Santos,
Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
Pre-Trial Brief
for the Defendant
Comes Now Defendant, thru and by the undersigned counsel, and to

this Honorable Court, most respectfully submits this Pre-Trial Brief and
GG. A statement of her willingness to enter into amicable settlement

or alternative modes of dispute resolution, indicating the desired terms
Defendant is willing to enter into any amicable

HH. Summary of admitted facts and proposed stipulations of facts:
 When Felix Gutierrez and defendant met each other

in 1994, the latter owns a canteen, sells figurines, and
engages in part time jobs such as cook, laundry
washer and a manicurist;
 Felix Gutierrez and defendant got married in March
01, 1999 and had, since then, lived as husband and
wife until Felix’ demise in July 26, 2015;
 The property subject matter of this case was acquired
by Felix and the defendant sometime in the year
2001, or already after their wedding;
II. The issues to be resolved:

action against the defendant;
 Whether or not defendant is entitled to damages.
JJ. Documents to be presented by the petitioner:
1 Certificate of Marriage of Felix and Defendant

2 Proof of Employment and Income
3 Deed of Sale dated October 07, 2011
Defendant reserves the right to mark other
KK. The number and names of the witnesses, the substance of their
witnesses.

Dinalupihan, Bataan, April 29, 2016.
Roniel D. Muñoz
Counsel for the Defendant
Roll No. 63074
PTR No. 3058381, 01/06/2016
IBP No. 924131, 01/06/2016
MCLE Compliance No. V-0018535 (valid from 04/15/2016 to 04/14/2019)
Copy furnished:
Atty. Jan Alexander E. Lim

3rd Floor 161-B Shaw boulevard cor.,
J.B. St., Mandaluyong City
Supreme Court
Branch 5
Dinalupihan, Bataan
Hazel Marie R. David-Dimacali,

Petitioner,

Based on Art. 35, Par. 1 of the Family
Code of the Phils.
Wilfredo H. Dimacali,
Respondent.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Petitioner

LL. A statement of their willingness to enter into amicable settlement or

MM. Summary of admitted facts and proposed stipulations of facts:
 Fact of marriage: Parties appeared to have been married on

June 25, 1993 as per their Marriage Contract;
 Fact of birth of parties’ children: Parties have two children,
namely: Llyzel May who was born on March 23, 1994 and Will
Mayrie who was born on May 23, 2003;
 Petitioner was born on May 8, 1976 as per her Certificate of
Live Birth;
 Petitioner was 17 years and 48 days old on June 25, 1993;
NN. The issues to be resolved:
 Whether or not there is legal ground to declare that the

marriage of the parties herein is a nullify based on Article 35,
par. 1 of the Family Code of the Philippines, considering that
petitioner was below 18 years old when she contracted
marriage with the respondent;
 Whether or not custody of their children should remain with
the petitioner.
OO. Documents to be presented by the plaintiff:
Exhibits Documents
A Notice of Appearance by the OSG dated January 28

2016
A-1 Letter of the OSG deputizing the OPP to assist them
in this case
B Non-Collusion Report dated December 14, 2015
C Marriage Contract
D Certificate of Live Birth of Llyzel May D. Dimacali
E Certificate of Live Birth of Will Mayrie D. Dimacali
G Certificate of Live Birth of Hazel Marie R. David
trial.
PP. The number and names of the witnesses, the substance of their
witnesses.
The petitioner will be presented as the lone witness. She

will prove that: she is married to the petitioner as they got married
on June 25, 1993; they have two children; she was born on May 8,
1976; when they got married she was 17 years and 48 days old or
below 18 years old; their children have been in her custody;
parties have been separated since 2012 and such other matters
germane to the instant case.
Dinalupihan, Bataan, April 27, 2016.

By:

IBP No. 924130, 01/06/2016
PTR No. 3058380, 01/06/2016
MCLE Compliance No. V 0004006 (valid from 04/15/2016 to 04/14/2019)
Roniel D. Muñoz
IBP No. 924131, 01/06/2016
PTR No. 3058381, 01/06/2016
MCLE Compliance No. V 0018535 (valid from 04/15/2016 to 04/14/2019)
Copy furnished:


Branch 3
Rizalina Jaraba, Represented by her

Attorney-In-Fact Vilma Paule
Tolentino,
Plaintiff,
-versus- Civil Case No. 10408

For: Recovery of Possession/Accion
Publiciana and Damages
Rolanda Jaraba,
Defendant.
x---------------------------------------------------------------------------------------------------x
Pre-Trial Brief
for the Plaintiff
Comes Now Plaintiff, thru and by the undersigned counsel, and to this
Honorable Court, most respectfully submits this Pre-Trial Brief and
QQ. A statement of their willingness to enter into amicable

Plaintiff is willing to enter into any amicable

RR. Summary of admitted facts and proposed stipulations of facts:
 Plaintiff is one of the registered owners of a property

located in Tenejero, Balanga City, Bataan, measuring
506 square meters and embraced in TCT No. 038-
2014008195 issued by the Registry of Deeds Province
of Bataan on December 4, 2014;
 TCT No. 038-2014008195 is a derivative of TCT No. T-
120148 which was then registered under the name of
Eduardo S. Jaraba;
 Eduardo Jaraba is the deceased husband of plaintiff
and the father of the other registered owners of the
property subject matter of this case;
 Plaintiff is the mother of Michelle Elaine, Paola and
Janice, all surnamed Jaraba and whose names are
recorded in TCT No. 038-2014008195 as owners;
 Subject property is declared for tax purposes under
the name of the plaintiff and her children under Tax
Declaration Property Index Number 204-01-019-30-
010-B;
 Plaintiff paid the realty taxes due the subject property
up to the year 2015 the latest Official Receipt is with
Number 01017571;
 Defendant duly received the demand letter dated
January 20, 2015 sent to him by the plaintiff on
February 4, 2015;
SS. The issues to be resolved:
 Whether or not the plaintiff has a valid cause of

 Who has the better right to possess and occupy
subject property;
 Whether or not plaintiff is entitled to damages.
TT. Documents to be presented by the petitioner:
A Special Power of Attorney executed by plaintiff in favor of

her attorney-in-fact Vilma P. Tolentino;
B TCT No. 038-2014008195
B-1 TCT No. T-120148
C Tax Declaration Property Index No. 204-01-019-30-010-B
D OR Number 01017571
E Demand Letter dated January 20, 2015
F Return Card
Plaintiff reserves the right to mark other

UU. The number and names of the witnesses, the substance of their
witnesses.

actual pre-trial conference proper.
Dinalupihan, Bataan, for the City of Balanga, Bataan, March 31, 2016.

Collaborating Counsel for the Plaintiff
Roll No. 40601
PTR No. 3058380, 01/06/2016
IBP No. 924130, 01/06/2016
MCLE Compliance No. IV-0006775
Copy furnished:
Atty. Fatima Anne C. Zamora

Public Attorney II
Branch 5
Dinalupihan, Bataan
Alicia C. Basco,
Plaintiff,

For: Specific Performance and
Damages
Emerita Lacson Lumanog,
Defendant.
X-------------------------------------------------------X

for the Plaintiff
VV. A statement of her willingness to enter into amicable settlement


settlement of the instant case with the defendant insofar as
allowed by law.
WW. Summary of admitted facts and proposed stipulations of facts:
 Existence of a contract of sale between the parties

herein concerning the two-door apartment and the lot
where it is erected in the agreed amount of One
Million One Hundred Pesos (P 1,100,000.00);
 Defendant agreed to execute the necessary Deed of
Sale, cause the subdivision of the property to separate
the property purchased by plaintiff, pay the mortgage
balance of the property and cause the titling of the
purchased property within one month from receipt of
the last payment
 Plaintiff was able to complete the payment of the
aggregate amount of One Million One Hundred Fifty
Pesos (P 1,150,000.00) on July 2, 2015;
 To date, there was no compliance of any of the above
covenants despite several demands to do so from the
plaintiff;
 Defendant received the demand letter sent by
plaintiff’s counsel but did not do anything about it;
XX. The issues to be resolved:
 Whether or not the Plaintiff is entitled to the relief sought in

her complaint;
 Whether or not defendant is liable to pay damages for her
 Whether or not defendant is liable to pay the amount of
of her rights in court.
YY. Documents to be presented by the petitioner:
SS. Electronic certified true copy of TCT No. T-84423

TT. Copy of the hand written agreement between the parties dated April 24,
2015
UU. Written acknowledgment receipt signed by the defendant dated
May 27, 2015
VV. Written acknowledgment receipt signed by the defendant dated
July 2, 2015
WW. Demand letter dated January 30, 2015
XX. E-1 Return card
YY. Certification (Pagpapatunay) issued by the Office of Barangay Rizal,
Dinalupihan, Bataan dated November 18, 2015
ZZ.The number and names of the witnesses, the substance of their

witnesses.

Dinalupihan, Bataan, March 08, 2016.
Roniel D. Muñoz
Roll No. 63074
PTR No. 3058381, 01/06/2016
IBP No. 924131, 01/06/2016
MCLE (Exempted)
Copy furnished:
Atty. Sheena E. Esteban-Bartolome

PAO, Dinalupihan, Bataan
Branch 5
Dinalupihan, Bataan
Carlito R. Serrano
Plaintiff,

For: Recovery of Possession and
Ownership and Damages
Ramon Fajardo, et. al.,

Defendants.
x---------------------------------------------------------------------------------------------------x
Pre-Trial Brief
for the Defendants
Comes Now Defendants, thru and by the undersigned counsel, and to

this Honorable Court, most respectfully submit this Pre-Trial Brief and
AAA. A statement of their willingness to enter into amicable

Defendants are willing to enter into any amicable

BBB. Summary of admitted facts and proposed stipulations of facts:

 Oliva Serrano is the mother of the defendants;
 In the year 1993, the subject property currently being
occupied by the defendants was given to their mother
by Ricardo Serrano, their grandfather;
 Genuineness and due execution of a last will and
testament dated November 05, 1990, executed by
Ricardo Serrano, devising a parcel of land (claimed by
plaintiff herein) to his children;
 The defendants and/or their mother did not sign any
document ceding their/her share over the subject
property in favor of the Plaintiff;
CCC. The issues to be resolved:
 Whether or not the plaintiff has a valid cause of

action against the defendants;
 Whether or not defendants are entitled to damages.
DDD. Documents to be presented by the petitioner:
1 Last will and testament of Ricardo Serrano dated November

05, 1990
2 Decision rendered by the Department of Agrarian Reform
Adjudication Board (DARAB), Dinalupihan, Bataan dated May
29, 1995 in the case entitled InicetaRazon et.al., v, Carlito
Serrano, Darab Case No. 157-94
3 And series Certificates of Live Birth of defendants
4 Decision rendered by the DARAB Central Office in Diliman,
Quezon City dated October 11, 2004

EEE. The number and names of the witnesses, the substance of their
witnesses.

Roniel D. Muñoz
Counsel for the Defendants
Roll No. 63074
PTR No. 3058381, 01/06/2016
IBP No. 924131, 01/06/2016
MCLE (Exempted)
Copy furnished:
Mr. Carlito Serrano

Brgy. Luacan Dinalupihan,
Bataan
Branch 5
Dinalupihan, Bataan
Wilfredo S. Manlulu, Irma S.

Manlulu and Ma. Angelita M.
Garcia,
Plaintiffs,
Spouses Rodolfo Manlulu Jr.

and Jocelyn A. Manlulu and
Carmela Manlulu,
Defendants.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Defendants Spouses Manlulu
Come Now Defendants Spouses Manlulu (“Defendants Spouses”), thru

and by the undersigned counsel, and to this Honorable Court, most
respectfully submit this Pre-Trial Brief and accordingly state as follows:
FFF. A statement of his willingness to enter into amicable settlement
Defendants Spouses are willing to enter into any

resolution.
GGG. Summary of admitted facts and proposed stipulations of facts:
 The father of the parties herein did not stay in Bataan

since 1976 until his demise in 2012;
 The property subject matter of this case, allegedly
owned by their parents, is not the same property
being occupied by the Defendants Spouses;
 The existence and due execution of a Decision of the
First Municipal Trial Court of Dinalupihan-Hermosa
dated March 3, 1997 in the case entitled Rodolfo
Manlulu, Jr., v. Wilfredo Manlulu, docketed as Civil
Case No. 1013;
 The complaint did not specify any boundaries or
description of the subject property;
HHH. The issues to be resolved:

action against the defendants spouses;
 Whether or not defendants spouses are entitled to
damages.
III. Documents to be presented by the petitioner:
1 and series Documents to show that Defendants Spouses

have ever since been gainfully engaged in
business
3 and series OR Nos. 0347943, 0259835 and 0259836
4 Notice of Assessment and Tax Bill
5 Decision of the First Municipal Trial Court of
Dinalupihan-Hermosa dated March 3, 1997 in
the case entitled Rodolfo Manlulu, Jr., v.
Wilfredo Manlulu, docketed as Civil Case No.
1013
Defendants Spouses reserve the right to mark
JJJ.The number and names of the witnesses, the substance of their

witnesses.

Dinalupihan, Bataan, February 29, 2016.
Roniel D. Muñoz
Counsel for Defendants Spouses Manlulu
Roll No. 63074
PTR No. 3058381, 01/06/2016
IBP No. 924131, 01/06/2016
MCLE (Exempted)
Copy furnished:
Atty. Edmundo S. Cari-an

Counsel for the Plaintiffs
Luacan Dinalupihan, Bataan
Branch 5
Dinalupihan, Bataan
Teresa Gutierrez-Aspirin and

Leonardo Gutierrez,
Plaintiffs,
Teresita Santos,
Defendant.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Defendant

KKK. A statement of her willingness to enter into amicable settlement

Defendant is willing to enter into any amicable
LLL. Summary of admitted facts and proposed stipulations of facts:
 When Felix Gutierrez and defendant met each other

in 1994, the latter owns a canteen, sells figurines, and
engages in part time jobs such as cook, laundry
washer and a manicurist;
 Felix Gutierrez and defendant got married in March
01, 1999 and had, since then, lived as husband and
wife until Felix’ demise in July 26, 2015;
 The property subject matter of this case was acquired
by Felix and the defendant sometime in the year
2001, or already after their wedding;
MMM. The issues to be resolved:

 Whether or not defendant is entitled to damages.
NNN. Documents to be presented by the petitioner:
1 Deed of Sale dated October 07, 2011

OOO. The number and names of the witnesses, the substance of their
witnesses.


Roniel D. Muñoz
Counsel for the Petitioner
Roll No. 63074
PTR No. 3058381, 01/06/2016
IBP No. 924131, 01/06/2016
MCLE (Exempted)
Copy furnished:
Atty. Jan Alexander E. Lim

3rd Floor 161-B Shaw boulevard cor.,
J.B. St., Mandaluyong City
Branch 5
Dinalupihan, Bataan
Wilfredo S. Manlulu, Irma S.

Manlulu and Ma. Angelita M.
Garcia,
Plaintiffs,
Spouses Rodolfo Manlulu Jr.

and Jocelyn A. Manlulu and
Carmela Manlulu,
Defendants.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Defendants Spouses Manlulu
Come Now Defendants Spouses Manlulu (“Defendants Spouses”), thru

and by the undersigned counsel, and to this Honorable Court, most
respectfully submit this Pre-Trial Brief and accordingly state as follows:
PPP. A statement of his willingness to enter into amicable settlement
Defendants Spouses are willing to enter into any

resolution.
QQQ. Summary of admitted facts and proposed stipulations of facts:
 The father of the parties herein did not stay in Bataan

since 1976 until his demise in 2012;
 The property subject matter of this case, allegedly
owned by their parents, is not the same property
being occupied by the Defendants Spouses;
 The existence and due execution of a Decision of the
First Municipal Trial Court of Dinalupihan-Hermosa
dated March 3, 1997 in the case entitled Rodolfo
Manlulu, Jr., v. Wilfredo Manlulu, docketed as Civil
Case No. 1013;
 The complaint did not specify any boundaries or
description of the subject property;
RRR. The issues to be resolved:

action against the defendants spouses;
 Whether or not defendants spouses are entitled to
damages.
SSS. Documents to be presented by the petitioner:
1 and series Documents to show that Defendants Spouses

have ever since been gainfully engaged in
business
3 and series OR Nos. 0347943, 0259835 and 0259836
4 Notice of Assessment and Tax Bill
5 Decision of the First Municipal Trial Court of
Dinalupihan-Hermosa dated March 3, 1997 in
the case entitled Rodolfo Manlulu, Jr., v.
Wilfredo Manlulu, docketed as Civil Case No.
1013
Defendants Spouses reserve the right to mark
TTT. The number and names of the witnesses, the substance of their
witnesses.

Roniel D. Muñoz
Counsel for Defendants Spouses Manlulu
Roll No. 63074
PTR No. 3058381, 01/06/2016
IBP No. 924131, 01/06/2016
MCLE (Exempted)
Copy furnished:
Atty. Edmundo S. Cari-an

Luacan Dinalupihan, Bataan
Branch 5
Dinalupihan,Bataan
Petition for Sole Care, Custody and

Control on the Persons of Minors,
Harold, Beverly and Harvey (All
Surnamed Biugos)
Jocelyn B. Visda, Represented by

her mother/attorney-in-fact Rustica
Visda,
Petitioner,
Neil M. Biugos,
Respondent.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Petitioner
Comes Now Petitioner, thru and by the undersigned counsel, and to
UUU. A statement of her willingness to enter into amicable settlement

Petitioner is willing to enter into an amicable

settlement with the respondent, should there be any.
VVV. Summary of admitted facts and proposed stipulations of facts:
 The existence and due execution of a Special Power of

Attorney dated January 8, 2015 executed by the
petitioner in favor of her mother to represent her in
this case;
 The existence and due execution of a certificate of
marriage of the parties as husband and wife as
registered with the National Statistics Office stating
that they got married on January 28, 1997 in
Dinalupihan, Bataan;
 The existence and due execution of the certificates of
live birth of petitioner’s children namely, Harold,
Beverly and Harvey, all surnamed Biugos;
 Parties herein are separated since the year 2001;
 Petitioner obtained a divorce decree in Australia;
WWW. The issues to be resolved:
 Whether or not there is valid ground to grant the

instant petition;
XXX. Documents to be presented by the petitioner:
A. Special Power of Attorney dated January 8, 2015

B. Certificate of marriage of the parties
C. Birth certificate of Harold V. Biugos
D. Birth certificate of Beverly V. Biugos
E. Birth certificate of Harvey V. Biugos
F. Divorce Decree in Australia
G. Information in Criminal Case No. GH-1175-01
Petitioner reserves the right to mark other
YYY. The number and names of the witnesses, the substance of their
witnesses.

Dinalupihan, Bataan, January 18, 2015.
Roniel D. Muñoz
Roll No. 63074
PTR No. 3058381, 01/06/2016
IBP No. 924131, 01/06/2016
MCLE (Exempted)
Copies furnished:
Office of the Provincial Prosecutor

Mr. Neil M. Biugos

Respondent
Kataasan Dinalupihan,
Bataan
Branch 5
Dinalupihan, Bataan
Francisco Visda, Jr.,

Petitioner,
Sheryll S. Vitug,
Respondent.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Petitioner
Comes Now Petitioner, thru and by the undersigned counsel, and to

ZZZ. A statement of his willingness to enter into amicable settlement

It being an annulment case, the above statement

may not be applicable.
AAAA. Summary of admitted facts and proposed stipulations of facts:
 The existence and due execution of the certificate of

marriage of the parties as husband and wife as
registered with the National Statistics Office stating
that they got married on May 20, 1995 in Orani,
Bataan;
 The date of birth of the respondent appearing on the
marriage certificate of the parties is October 2, 1976;
 The existence and due execution of a certificate of live
birth of the respondent as registered with the
National Statistics Office stating that she was born on
October 2, 1978 in Floridablanca, Pampanga;
 At the time their marriage was solemnized,
respondent was only 16 years of age;
 During their wedlock parties had two children;
 Petitioner has not reneged on his duty to support his
children despite the fact that the children are under
the custody of the respondent;
 Parties did not acquire properties under their names;
BBBB. The issues to be resolved:

instant petition;
 Whether or not petitioner is entitled to visitorial
rights or temporary custody of their children.
CCCC. Documents to be presented by the petitioner:
H. Certificate of marriage of the parties

I. Birth certificate of Respondent
J. Birth certificate of Dan Van Jethro
C-1 Birth certificate of Dan Van Jaster

DDDD. The number and names of the witnesses, the substance of their
witnesses.

Dinalupihan, Bataan, December 16, 2015.
Roniel D. Muñoz
Roll No. 63074
PTR No. 2505401, 01/06/2015
IBP No. 924066, 01/05/2015
MCLE (Exempted)
Copy furnished:

Dinalupihan-Hermosa
Province of Bataan
Erlinda R. Marcelo, Amelia R. Ng,

Manuel C. Reyes, Violeta R. Lardizabal,
Natividad R. Bantay, and Eduardo C.
Reyes, represented by their Attorney-
in-Fact,Ruby Anna V. Mallari,
Plaintiffs,
Eduardo Nicdao, Joined by His

Wife,
Defendants.
X---- --------------------------------------- -----------X

for the Plaintiffs
Come Now Plaintiffs, thru and by the undersigned counsel, unto this
F. A statement of their willingness to enter into amicable settlement or


allowed by law.
G. Summary of admitted facts and proposed stipulations of facts:
 Plaintiffs are all represented herein by their attorney-

in-fact, Ruby Anna V. Mallari, by virtue of the Special
Powers of Attorney executed on July31, 2015 and
September 01, 2015;
 Plaintiffs are the absolute and registered owners of the
subject property located at Roxas, Dinalupihan, Bataan,
as evidenced by the Transfer Certificate of Title No. T-
189544 issued by the Registry of Deeds for the
Province of Bataan on March 12, 1997;
 Said property is declared for tax purposes under the
names of the plaintiffs as per Tax Declaration No.
022922;
 Realty taxes due the subject property have been
religiously paid by the plaintiffs until the year 2015, as
evidenced by Official Receipt No. 0328484;
 Existence and due execution of a contract of lease
entered into in July 31, 2013 between defendant as
lessee and one of the co-owners, Eduardo C. Reyes as
lessor;
 Existence and enforceability of a provision in the said
contract of lease which states that the property is for
sale and that “the Lessee agrees to abandon or
surrender physical possession upon notice of the sale,
or whenever needed by the lessor for any reason”;
 Sometime in the early part of 2015, plaintiff Eduardo
Reyes demanded the defendants to vacate the subject
property because the same will already be utilized by
the Plaintiffs; nevertheless, he refused to vacate the
same;
 Plaintiffs’ counsel sent a demand letter dated January
30, 2015 addressed to the defendants;
 The said demand letter was received by the defendant
on February 06, 2015 as evidenced by the
corresponding return card;
property;
H. The issues to be resolved:
 Whether or not the Plaintiffs are entitled to the possession of

the subject property;
same and to restore possession thereof to the plaintiffs;
I. Documents to be presented by the plaintiffs:
ZZ. Special Powers of Attorney executed on July 31, 2015

A-1 Special Powers of Attorney executed on September 01, 2015
AAA. Transfer Certificate of Title No. T-189544
BBB. Tax Declaration No. 022922
CCC. Official Receipt No. 0328484
DDD. Contract of Lease dated July 31, 2013
EEE. Demand letter dated January 30
F-1 Corresponding Return Card
Plaintiffs reserve the right to mark other documents during trial.
J. The number and names of the witnesses, the substance of their

witnesses.

Dinalupihan, Bataan, November 25, 2015.
Roniel D. Muñoz
IBP No. 924066, 01/05/2015
PTR No. 2505401, 01/06/2015
MCLE Compliance (Exempted)
Copy furnished:
Atty. Leonardo L. Gonzales Jr.

Baraca, Subic, Zambales
Explanation:
The above pleading will be served to the opposing counsel by

registered mail due to the distance involved and lack of staff to cause
personal service as permitted under the rules.
Branch 1
Balanga, Bataan
Cherrielyne Murielzeus (CMZ)

Builders Corporation,
Represented by Its President
Engr. Eliseo B. Naguit,
Plaintiff,
- versus - Civil Case No. 10253
For: Collection & Damages
With Prayer for Issuance of Writ
of Prel. Attachment
Benjamin Alonzo, Kyoryo Inc.,
and Spouses Ryoichi and
NonabelleTomasada,
Defendants.
X--------------------------------------------------x

for the Plaintiff
EEEE. A statement of its willingness to enter into amicable settlement


settlement of the instant case with the defendant insofar as
allowed by law.
FFFF. Summary of admitted facts and proposed stipulations of facts:
 Plaintiff is a corporation engaged in business as general

builders and industrial plants, duly organized and
existing under the laws of the Republic of the
Philippines as evidenced by its Certificate of
Incorporation;
 Plaintiff is being represented herein by its President
and General Manager, Engr. Eliseo B. Naguit by virtue
of a Board Resolution;
 Sometime in February 2006, all defendants named
above jointly represented and negotiated with the
plaintiff for their pressing need of heavy equipments to
be used on the project awarded to them by the Bases
Conversion Development Authority (BCDA);
 They used William L. Tan Construction to get the
project;
 During that time defendant Alonzo was the Vice-
Governor of Bataan and could not enter into
transaction with the plaintiff in his personal capacity;
 Plaintiff prepared a quotation dated February 3, 2006
addressed to defendant William L. Tan Construction as
per instruction of the defendants;
 The quotation was accepted, confirmed and affirmed
by defendants thru co-defendant Ryoichi Tomasada on
February 6, 2006 thru Purchase Order No. 06-01206 ;
 Plaintiff then delivered to defendants the following
equipments thru Delivery Receipts, to wit:
Ref. Equipment
DR No. 032 2 units 133KVA Cummins Generator

Set
1 unit 125KVA Yenmar Generator Set
DR No. 033 1 unit 25 Tons Rough Terrine Crane

“Tadano”
DR No. 035 1 unit 375 CFM

652 pcs. Fixed Clamp
430 pcs. Swivel Clamp
DR No. 046 1 unit 125 CFM “Denyo” Cinoresso

w/2 sm
Battery
DR No. 050 1 unit 110 KVA Generator Set w/2 pcs

Battery
 Total cost of rental of equipment delivered by plaintiff
to defendants is P 2,864,743.00;
 Plaintiff made Billings with Summaries and were all
received by defendants;
 Total payment made by the defendants, thru defendant
Alonzo, to plaintiff is P 480,000.00 leaving a balance of
P 2,384,743.99;
 Defendant Alonzo’s checks were issued for the said
payment. However, the other checks which he issued
in favor of the plaintiff for the payment of their
obligation were dishonored by the bank;
 Several demand letters had been sent to defendants
for the collection of unpaid rental payment of P
2,384,743.99 but to no avail;
 Despite receipt thereof, defendants failed to pay their
obligation to the plaintiff;
GGGG. The issues to be resolved:
 Whether or not the Plaintiff is entitled to the payment of the

remaining balance in the amount of P 2,384,743.99;
 Whether or not defendantsare liable to paydamages for their
HHHH. Documents to be presented by the plaintiff:
FFF. Plaintiff’s Certificate of Incorporation

GGG. Secretary’s Certificate
HHH. Plaintiff’s Quotation dated February 3, 2006
III. Purchase Order No. 06-01206
JJJ. Delivery Receipts of the Equipments
KKK. Computation of the partial payments and the remaining balance
LLL. Demand letter dated January 14, 2014
IIII.The number and names of the witnesses, the substance of their

witnesses.

Dinalupihan, Bataan, for Balanga City, Bataan, November 19,2015.
Roniel D. Muñoz
IBP No. 924066, 01/05/2015
PTR No. 2505401, 01/06/2015
Copies furnished:
Atty. David Paguio Jr.

2nd Flr. SHP Bldg., J.P. Rizal St.,
Atty. Nelson A. Clemente

No. 10 Nery St. corner Rosary St.,
Remmanville Executive Village,
Parañaque City
Explanation:
The above pleading will be served to defendants by registered mail

due to the distance involved and lack of staff to cause personal service as
permitted under the rules.
BRANCH 49
Guagua, Pampanga
In Re: Allowance of Will

of Felisa S. Jimenez
Carlos S. Jimenez,
Petitioner,
-versus – Sp. Civil Action No. G-14-671
Ruben S. Jimenez,
Respondent,
X --------------------------------------------------------X

for the Petitioner
Comes Now Petitioner, thru and by the undersigned counsel, unto this
JJJJ. A statement of his willingness to enter into amicable settlement

Petitioner is willing to enter into reasonable

amicable settlement of the instant case with the
respondent insofar as allowed by law.
KKKK. Summary of proposed stipulations of facts:

 On February 21, 2006, a petition was filed for the
Allowance of the Will of Felisa S. Jimenez;
 The last will and Testament of Felisa S. Jimenez was
admitted to probate in a decision dated May 12, 2008;
 Petitioner was the court appointed administrator of
the above-mentioned will;
 The above-mentioned decision has attained its
finality;
 Sometime in 2007, a Petition for Issuance of
Preliminary Injunction was filed by the petitioner
against the respondent but the same was withdrawn
upon manifestation of commitment by the
respondent, thru counsel, that he will no longer lease
the properties to other persons;
 Respondent again leased the inherited properties
subject of administration without the consent of the
petitioner and their other siblings;
 Petitioner sent demand letters to the respondent and
the lessees of the subject properties to vacate the
same;
 Said demand letters were duly received by the
intended recipients;
 Despite receipt of the said letters, no one responded
nor vacated the subject property;
LLLL. The issues to be resolved:
 Whether or not the respondent is liable for indirect

contempt;
 Whether the petitioner is entitled to damages.
MMMM. Documents to be presented by the petitioner:
1 Petition for the Allowance of the Will of Felisa S. Jimenez

2 Decision dated May 12, 2008 in case no. Sp. Proc. No. G-06-
1942
3 Order dated July 07, 2007 in case no. Sp. Proc. No. G-06-1942
4 Demand Letter addressed to the respondent and the lessees
D-3 Corresponding Return Cards
Petitioner reserves the right to mark other documents

during trial.
NNNN. The number and names of the witnesses, the substance of their
witnesses.

Dinalupihan, Bataan, for Guagua, Pampanga, November 02, 2015.
Roniel D. Muñoz
Counsel for Petitioner
IBP No. 924066, 01/05/2015
PTR No. 2505401, 01/06/2015
Copy furnished:
Atty. Edegard C. Miano

San Matias, Guagua, Pampanga
Third Judicial
BRANCH 74
Olongapo City
Sps. Rubimeo Aguirre,

Plaintiffs,
-versus – Civil Case No. 79-0-14

For: Collection of Sum of Money
Julito Florendo, et. al.,

Defendants,
X -------------------------------------------------------X
Pre-Trial Brief
for the Defendants
Come Now Defendants, thru and by the undersigned counsel, unto this
Honorable Court, most respectfully submit this Preliminary Conference Brief
and accordingly state as follows:
OOOO. A statement of their willingness to enter into amicable

Defendantsare willing to enter into reasonable

amicable settlement of the instant case with the
plaintiffs insofar as allowed by law.
PPPP. Summary of proposed stipulations of facts:
 The plaintiffs are actually residents of Novaliches,

Quezon, City;
 Defendants Julito Florendo and Maria Salvacion are
the true and lawful owners of the property subject
matter of this case;
 TCT No. T-206925 in the name of Marcelina Pangilinan
is not the same property sold by the defendants to
the plaintiffs;
 The Contract to Sell dated March 18, 2014 entered
into between the parties is still valid and existing up
to the present time;
 Defendant Paguio is not a party to the said contract;
 There was no contract entered into between the
plaintiff and defendant Paguio;
 Pursuant to the provisions of the Contract to Sell
dated March 18, 2014 entered into between the
parties, the balance of Php 1,300,000.00 (One Million
Three Hundred Thousand Pesos) has not yet been
paid;
QQQQ. The issues to be resolved:
 Whether or not the plaintiffs have a cause of action

against the defendants;
 Whether the defendants are entitled to the
counterclaims stated in their answer.
RRRR. Documents to be presented by the petitioner:
5 Official Receipt No. 0268518

6 Contract to Sell dated March 18, 2014
7 Manager’s Check No. 0000301326
8 TCT No. T-206925
9 Letter addressed to the plaintiffs dated June 30, 2014
5-A Corresponding Return Card
10 Letter addressed to Atty. Andrew Penular dated June 30, 2014
6-A Corresponding Return Card
Defendants reserve the right to mark other

SSSS. The number and names of the witnesses, the substance of their
witnesses.

Dinalupihan, Bataan, for Olongapo City, October 07, 2015.
Roniel D. Muñoz
IBP No. 924066, 01/05/2015
PTR No. 2505401, 01/06/2015
Copy furnished:
Atty. Andrew M. Penular
Unit 038 West Gate Suites
Sampson Road, Subic Bay Freeport Zone
Olongapo City

National Capital Judicial Region
BRANCH 231
Pasay, City
Toyota Financial Services
Phils., Corp.,
Plaintiff,
versus – Civil Case No. R-PSY-12-12079-CV

For: Recovery of Possession with
Replevin
Sps. Alyn D. Enriquez,

Faustino Enriquez, Jr. and
John Doe,
Defendants,
X -------------------------------------------------------X
Sps. Alyn D. Enriquez and

Faustino Enriquez, Jr.,
Third Party Plaintiffs,
versus –
Toyota Motor Philippines,

Toyota San Fernando
(Pampanga), Leo Malit,
DondeQuiambao and
John Doe,
Third Party Defendants.
X -------------------------------------------------------X
Pre-Trial Brief
for the Third Party Defendants
LEO MALIT and DONDE QUIAMBAO
Come Now Third Party Defendants LEO MALIT and DONDE

QUIAMBAO, thru and by the undersigned counsel, unto this Honorable
Court, most respectfully submit this Preliminary Conference Brief and
K. A statement of their willingness to enter into amicable settlement or

Third PartyDefendantsLEO MALIT and DONDE

QUIAMBAOare willing to enter into reasonable amicable
settlement of the instant case with the plaintiff insofar as
allowed by law.
L. Summary of proposed stipulations of facts:
 Third party defendants LEO MALIT and DONDE

QUIAMBAO were employees of Toyota Pampanga at
the time the alleged incident subject matter of this
case happened;
 As employees of Toyota Pampanga third party
defendants LEO MALIT and DONDE QUIAMBAO
suggested to the third party plaintiffs that the subject
vehicle may be reacquired thru Toyota’s “trade in”
program or the “assumed balance” scheme;
 The third party plaintiffs chose the “assumed balance”
scheme and entered into an agreement with a certain
Alim Cuason;
 The subject vehicle was given by the third party
plaintiffs to Alim Cuason and the latter had already
issued several checks as payment for the said vehicle;
 There was no contract between the third party
plaintiffs and Third party defendants LEO MALIT and
DONDE QUIAMBAO;
 Third party defendants LEO MALIT and DONDE
QUIAMBAO never had possession of the subject
vehicle;
 Prior to the filing of the third party complaint herein,
Third party plaintiffs had already filed estafa and
carnapping cases against herein Third party
defendants LEO MALIT and DONDE QUIAMBAO;
 The said cases were not mentioned by the Third party
plaintiffs in their Verification and Certification of Non-
Forum Shopping;
M. The issues to be resolved:
 Whether or not the third party plaintiffs have a cause

of action against the third party defendants LEO
MALIT and DONDE QUIAMBAO;
 Whether the third party defendants LEO MALIT and
DONDE QUIAMBAO are entitled to the counterclaims
stated in their answer.
N. Documents to be presented by the petitioner:
11 Investigation Data Form
Third party defendants LEO MALIT and DONDE

QUIAMBAO reserve the right to mark other documents
during trial.
O. The number and names of the witnesses, the substance of their

witnesses.

Dinalupihan, Bataan, September 25, 2015.
Roniel D. Muñoz
Counsel for the Third Party Defendants
LEO MALIT and DONDE QUIAMBAO
IBP No. 924066, 01/05/2015
PTR No. 2505401, 01/06/2015
Copies furnished:
Atty. Chelin Y. Dayrit

Counsel for Defendants and Third-Party Plaintiffs
Sto. Cristo, Guagua, Pampanga
Atty. Gerard M. Sayas

Counsel for Plaintiff
Cortel Law Office
Suite 1015, 10th Floor Cityland Condominium 10 Tower 1
Ayala Ave., cor. HV Dela Costa St.,
Makati City
Office of the President of the Philippines
HOUSING AND LAND USE REGULATORY BOARD
Northern Tagalog Regional Field Office III
3rd Floor Insular Life Building
San Fernando City, Pampanga
Beverly Heights V Subdivision

Homeowners’ Association,
Represented by Christine H.
Complainant,
- versus – HLURB Case No. NTR-REM-

072415-676
VJEJ Properties and Development,

Inc., Officers and Board of
Directors,
Respondents.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
Pre-Trial Brief
for the Complainant
Comes Now Complainant, thru and by the undersigned counsel, and to
TTTT. A statement of their willingness to enter into amicable

Complainant is willing to enter into compromise agreement

with the respondents for the completion of amenities which were
left unfinished by the latter.
UUUU. Summary of admitted facts and proposed stipulations of facts:
Admitted facts:
 Respondent is the developer of Beverly Heights V Subdivision
located in Cataning (Roman Hiway), Hermosa, Bataan;
 In year 2011 respondent stopped the development of the
subdivision;
 Road and other infrastructure were not yet turned over to the
local government unit;
 Complainant is duly registered with the HLURB as a subdivision

association;
 Respondent failed to finish the amenities of the subdivision.
VVVV. The issues to be resolved:
 Whether or not respondents should be directed to specifically

performed the completion of all the amenities in the
subdivision, particularly the perimeter fence, turn-over of
electrical distribution to Penelco, rehabilitation of distribution
lines, increase of its share in the maintenance of the
subdivision, completion of roads, among others;
 Whether or not respondents are liable to pay damages to
complainant by reason of their failure to provide the amenities
it had promised to their buyers.
WWWW. Documents to be presented by the plaintiff:
Exhibits Documents
A Board Resolution
A-1 Secretary’s Certificate
B Letter dated April 16, 2011
C Letter dated May 5, 2014
D Pictures of incomplete fence
E Demand Letter
Complainant reserves the marking of other documents in the course of the

trial.
XXXX. The number and names of the witnesses, the substance of their
witnesses.

Dinalupihan, Bataan, for the City of San Fernando, Pampanga,

September 22, 2015.
Roniel D. Muñoz
Counsel for the Complainant
IBP No. 924066, 01/05/2015
PTR No. 2505401, 01/06/2015
Copy furnished:
RRV Legal Consultancy Firm

Counsel for the respondents
Unit 303 C. C Castro International Building
No. 38 Timog Avenue, Quezon City
Explanation:
Due to the distance involved and lack of staff to cause personal service
and filing, the above pleading will be served to complainant and will be filed
with the Honorable Board by registered mail as permitted under the rules.

BRANCH 69
Iba, Zambales
SPS. ILDEFONSO ANULAO AND

GRACE Q. ANULAO,
Plaintiffs,
- versus – Civil Case No. 3750

MA. LUZ M. DIVINAGRACIA and
ROMEO A. LIZARDO and all persons
acting under their authority,
Defendants.
X------------------------------------------------------- X
Pre-Trial Brief
for the Defendant
MA. LUZ M. DIVINAGRACIA
Comes Now Defendant MA. LUZ M. DIVINAGRACIA, thru and by the

undersigned counsel, unto this Honorable Court, most respectfully submits
this Pre-Trial Brief and accordingly states as follows:
P. A statement of their willingness to enter into amicable settlement or

Defendant Divinagracia is willing to enter into reasonable

amicable settlement of the instant case with the plaintiff insofar as
allowed by law.
Q. Summary of admitted facts and proposed stipulations of facts:
 The subject property was purchased by defendant Divinagracia

from Luis Araman;
 Defendant Divinagracia had a reasonable ground to believe
that Luis Araman was the owner of the subject property which
she bought because such fact was reflected in the title, tax
declaration and the certification from the Provincial Assessor
of Iba Zambales;
 A Certificate Authorizing Registration (CAR) was issued in the
name of defendant Divinagracia;
 A Certification from the office of the Provincial Treasurer on
the payment of transfer taxes was issued in the name of
defendant Divinagracia;
 On June 24, 2014, the Registry of Deeds of Zambales issued
TCT No. 59558 in the name of defendant Divinagracia;
 Tax declaration no. 011-0002 was issued in the name of
 Defendant Divinagracia had no knowledge as to the execution
and contents of the alleged Extra-judicial Settlement of Estate
and the Deed of Sale between Eufemia Araman and the
Plaintiffs;
R. The issues to be resolved:
 Whether or not the plaintiffs have a cause of action against

 Whether defendant Divinagracia is entitled to the
counterclaims stated in her answer.
S. Documents to be presented by the petitioner:
12 Special of Power of Attorney (SPA) executed by Ma. Luz Divinagracia in

favor of Rosalinda O. Divinagracia
13 TCT No. 59558 issued under the name of the defendant Divinagracia
14 Deed of Absolute Sale between Luis Araman and defendant Divinagracia
15 Tax declaration No. 011-0207
16 Certification from the Provincial Assessor of Iba Zambales
17 Certificate Authorizing Registration (CAR) issued in the name of defendant
Divinagracia
18 Certification from the office of the Provincial Treasurer on the payment of
transfer taxes issued in the name of defendant Divinagracia
19 Tax Declaration No. 011-0002 issued in the name of defendant
Divinagracia
20 Official Receipts evidencing the payment of realty taxes issued in the
name of the defendant Divinagracia
Defendant Divinagracia reserves the right to mark other

T. The number and names of the witnesses, the substance of their

witnesses.


Roniel D. Muñoz
Counsel for Defendant Ma. Luz Divinagracia
IBP No. 924066, 01/05/2015
PTR No. 2505401, 01/05/2015
Copy furnished:
Atty. Sancho A. Abasta, Jr.

Iba, Zambales
Branch 4
Mariveles, Bataan
[Stationed at Balanga City]
Alejandro M. Jaime,
Petitioner,
- versus – Civil Case No. 991-ML
Mary Rose Calamba-Jaime,

Respondent.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
Petitioner’s
Pre-Trial Brief
Comes Now Petitioner, thru the undersigned counsel, unto this

YYYY. Statement of parties’ willingness to enter into amicable

desired terms thereof:
Considering that this is a case for declaration of nullity,

settlement may not be applicable.
ZZZZ. A summary of admitted facts and propose stipulation of facts:
Proposed Stipulation of Facts
 Fact of Marriage of Parties;

 Fact of Birth of Parties’ child named Kenneth Ahl
Calamba Jaime;
 The respondent had deprived petitioner the custody
of their child; and
 Parties did not acquire properties during their
consortium;
AAAAA. The issues to be tried or resolved:
 Is there a valid ground to declare the marriage of the

parties as an absolute nullity?
 Who is entitled to the custody over their child?
BBBBB. Documents to be presented:
Petitioner intends to present the following

documents:
 Certificate of Marriage of the Parties;

 Certificate of Live Birth of Kenneth Ahl Calamba
Jaime;
 Psychological Evaluation Report of Ruben Leo
Manrique
Petitioner reserves the right to present additional

evidence during the course of the trial.
CCCCC. The number and names of the witnesses, the substance of their
witnesses.

Dinalupihan, Bataan, for Balanga City,Bataan, July 15, 2015.

Roniel D. Muñoz
IBP No. 924066, 01/05/2015
PTR No. 2505401, 01/05/2015
Copy furnished:

Copies furnished:Republic of the Philippines
Branch 5
Dinalupihan, Bataan
Elaine Grace V. Estrella-Santiano,

Petitioner,
Raul Michael J. Santiano,

Respondent.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
Petitioner’s
Pre-Trial Brief
Comes Now Petitioner, thru the undersigned counsel, unto this

DDDDD. Statement of parties’ willingness to enter into amicable

desired terms thereof:
Petitioner is willing to enter into reasonable compromise
agreement with the respondent in as far as it is allowed by
law and provided that it be reasonable and justifiable.
EEEEE. A summary of admitted facts and propose stipulation of facts:
Proposed Stipulation of Facts1
 Fact of Marriage of Parties

 Fact of Birth of Parties’ child named Aldwin S. Samia;
 The child has been in the custody of the petitioner; and
 Parties did not acquire properties during their
consortium;
 Petitioner underwent psychological evaluation/test
FFFFF. The issues to be tried or resolved:
 Whether or not parties’ marriage is a nullity or could

be declared as null and void pursuant to Art. 36 of the
Family Code of the Philippines
 Custody and/or visitorial rights of the parties over their

child
GGGGG. Documents to be presented:

documents:
 Marriage Contract of the Parties;

 Birth Certificate of Aldwin S. Samia;
Manrique
 Judicial Affidavit of Petitioner
 Judicial Affidavit of Ruben Leo Manrique

1
Respondent did not file his Answer in this case.
HHHHH. The number and names of the witnesses, the substance of their
witnesses.

Dinalupihan, Bataan, for Mariveles, Bataan July 14, 2015.
Copies furnished:
FIRST MUNICIPAL CIRCUIT TRIAL COURT
Dinalupihan-Hermosa
Province of Bataan
Shane Edeen Bajada-Caferra,

Plaintiff,

For: Damages
Christopher K. Peñaflor
a.k.a. Ginger/Tophey Peñaflor,
Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
Pre-Trial Brief
for the Plaintiff
Honorable Court, most respectfully submits this Preliminary Conference Brief

settlement of the instant case with the plaintiff insofar as allowed
by law.
 Plaintiff entered into a written contract for make-up services

with the defendant for the former’s wedding preparation and
celebration;
 The contract price of Php 10, 000 was already fully paid by the
plaintiff;
 During the wedding day, defendant collected additional
expenses (meals and others) from plaintiff which are not
included in the contract;
 Thereafter, defendant started to make offensive, indecent and
inappropriate posts and comments on his facebook account
against and to the prejudice of the plaintiff;
 Defendant has 2,585 friends, more or less, on facebook and 18
of which are his mutual friends with plaintiff;
 On July 13, 2014, in the Office of Barangay JC Payumo, Jr.,
defendant admitted having posted said comments against
plaintiff;
IIIII. The issues to be resolved:
 Whether or not the Plaintiff is entitled to damages for the

wrongful, deliberate, and malicious act of the defendant;
 Whether or not defendant is liable to pay the amount of
of her rights in court.
JJJJJ. Documents to be presented by the petitioner:
MMM. Hair and make-up Service Contract between the plaintiff and the
defendant
NNN. Statement of account of Buma Hotel and Restaurant with
photoshoot fee
OOO. Copy of the profile showing the number of friends of defendant on
facebook
PPP. Facebook post of defendant on July 11, 2014
QQQ. Facebook post of defendant on July 12, 2014
RRR. Facebook post of defendant on July 12, 2014
SSS. Facebook post of defendant on July 12, 2014
TTT. Private messages of plaintiff and defendant on Facebook
UUU. Blotter of Office of Barangay JC Payumo, Jr. on July 13, 2014
Plaintiffreserves the right to mark other documents during trial.
KKKKK. The number and names of the witnesses, the substance of their
witnesses.

Dinalupihan, Bataan, 31 March 2015.
Roniel D. Muñoz
IBP No. 924066, 01/05/2015
PTR No. 2505401, 01/05/2015
Copy furnished:
Atty. Sheena E. Esteban-Bartolome

New Justice Hall Building
Dinalupihan, Bataan
Branch 5
Dinalupihan, Bataan
Peñafrancia R. Amorguis,
Plaintiff,
Spouses Conrado Tuazon Sr.

Et. Al.,
Defendants.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
Pre-Trial Brief
for Defendant Al Malibiran
Comes Now Defendant Al Malibiran, thru and by the undersigned
counsel, and to this Honorable Court, most respectfully submits this Pre-Trial
LLLLL. A statement of their willingness to enter into amicable

Defendant Malibiran is willing to enter into reasonable

compromise agreement.
MMMMM. Summary of admitted facts and proposed stipulations of

facts:
 Defendant Al Malibiran had no transaction with the Plaintiff

and/or the other Defendants in this case;
 There was no evidence to prove the existence of the alleged
sale of the land subject matter of this case between Defendant
Al Malibiran and the other defendants in this case.
 The other defendants in this case denied selling and conveying
the said parcel of land to Al Malibiran;
 Defendant Al Malibiran is not a real party-in-interest in this
case;
 No demand letter was sent by Plaintiff to Defendant Al
Malibiran prior to the filing of the instant case;
NNNNN. The issues to be resolved:
 Whether or not Defendant Al Malibiran is a real party-in-

interest in this case;
 Whether or not Defendant Al Malibiran should be dropped as a
Defendant in the instant case; and
 Whether or not Defendant Al Malibiran is entitled to his
counter-claims and/or damages.
OOOOO. Documents to be presented by the plaintiffs:
1. Answer of Conrado Tuazon Jr. dated April 1, 2011.
Defendant Al Malibiran reserves the right to mark other

PPPPP. The number and names of the witnesses, the substance of their
witnesses.

Roniel D. Muñoz
Counsel for Defendant Malibiran
Roll No. 63074
PTR No. 2505401, 01/06/2015
IBP No. 924066, 01/05/2015
MCLE (Exempted)
Copy furnished:
Atty. Carmelita Reyes Eleazar

UNit II B-19, Victoria Towers Condominium
79 Panay Ave. cor, Timog Ave.,
Quezon City
FIRST MUNICIPAL CIRCUITTRIAL COURT
Dinalupihan-Hermosa
Province of Bataan
TAISHIN REALTY DEVT. CORP
Rep by JENNEN GARCIA,
Plaintiff,
KATHERINE RUMERAL,
Defendant.
X------------------------------------------------------- X
Pre Trial Brief

for the Defendant
Comes Now Defendant, thru and by the undersigned counsel, unto this
Honorable Court, most respectfully submits this Preliminary Conference Brief
U. A statement of their willingness to enter into amicable settlement or

Defendant is willing to enter into reasonable amicable

settlement of the instant case with the plaintiff insofar as allowed
by law.
V. Summary of admitted facts and proposed stipulations of facts:
 The subject property was purchased by one Frances Velasco

from the plaintiff;
 The titles covering the property are registered under the name
of Frances Velasco;
 The subject property is financed by the Home Development
Mutual Fund (HDMF) or the Pag-Ibig Fund;
 A Deed of Conditional Sale was executed by the Defendant and
Frances Velasco sometime in 2011;
 Defendant is in possession of the property;
 Defendant had already paid Velasco and had also paid the
monthly amortization with HDMF;
 Defendant is legally married to Glenn Rumeral;
 Plaintiff did not implead defendant’s husband in this case.
W. The issues to be resolved:
 Whether or not the plaintiff has a cause of action against the

defendant;
 Whether or not the case should be dismissed for failure of the
plaintiff to implead defendant’s husband as party defendant
and for such other grounds allowed under the Rules;
 Whether the defendant is entitled to the counterclaims stated
in her answer.
X. Documents to be presented by the petitioner:
21 Deed of Conditional Sale between Velasco and defendant

22 Evidence of payment by defendant to Velasco
23 Receipts issued to Velasco by HDMF
24 Receipts of payment by defendant to Velasco
25 Screen print of Sulit.Com.Ph offering the subject property for sale stating
that the status of the property is “foreclosed”
Defendant reserves the right to mark other documents during

trial.
Y. The number and names of the witnesses, the substance of their

witnesses.

Dinalupihan, Bataan, 09 February, 2015.

Roniel D. Muñoz
IBP No. 924066, 01/05/2015
PTR No. 2505401, 01/06/2015
Copy furnished:
ATTY. ARCHIE PAUL MUYRONG

Unit 2E Rongui Bldg., Mac Arthur Highway,
Telabastagan, City of San Fernando
Pampanga

Supreme Court
Dinalupihan-Hermosa
Province of Bataan
Sps. Ramon T. Navarro and Mrs.
Helen E. Navarro represented by
their Atty-in-Fact Liwayway M.
Grumal,
Plaintiff,

For: Annulment and Cancellation
of TCT No. 038-2-12011086 with
Reconveyance of Property and
Damages
Sps. Luisa A. Stahl and Hans

Juergen-Stahl, Et. Al.,
Defendants.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Plaintiffs
Come Now Plaintiffs, thru and by the undersigned counsel, and to this
Honorable Court, most respectfully submit this Pre-Trial Brief and accordingly
state as follows:
QQQQQ. A statement of their willingness to enter into amicable

Plaintiffs are willing to enter into compromise agreement

that is reasonable and just.
RRRRR. Summary of admitted facts and proposed stipulations of facts:
 Plaintiff and defendant Aurea are siblings;

 Defendant Aurea is one of the owners of a property located in
Pinulot, Dinalupihan, Bataan, measuring 240 square meters
and covered by TCT No. 190796;
 Subject property is declared for tax purposes under the name
of Sps. Ricardo and Aurea Fernandez;
 The execution of Real Estate Mortgage by the defendants as
mortgagors dated June 1, 2012;
 The receipt of the demand letters sent by plaintiff to
defendants dated August 4, 2014;
 The referral of the matter to the Office of Barangay Happy
Valley, Dinalupihan, Bataan;
 The payment by the plaintiff of the realty taxes due the subject
property up to the year 2013;
SSSSS. The issues to be resolved:
 Whether or not plaintiff has cause of action against

defendants;
 Whether or not defendants should execute Deed of Sale of the
subject property in favor of the plaintiff in compliance with the
Real Estate Mortgage they executed on June 1, 2012;
 Who is now the owner of the subject property;
 Whether or not plaintiff is entitled to damages by reason of
the acts of the defendants.
TTTTT. Documents to be presented by the plaintiff:
Exhibit Documents
A TCT No. 190796

B Real Estate Mortgage
C Demand Letter
C-1 Return Card
D Certificate to file action in Court
E Tax Declaration Number 05886
F OR No. 0205287
UUUUU. The number and names of the witnesses, the substance of their
witnesses.


Roniel D. Muñoz
IBP No. 969003, 04/23/2014
PTR No. 2328773, 09/08/2014
Copy furnished:
Atty. Edwin C. Torres

Supreme Court
Municipal Trial Court in Cities
Branch 4
Olongapo City
Limanch-O-Hotel and Leasing

Corporation and its President and
General Manager Conrado L. Tiu,
represented by Carolle Jane O.
Gingco,
Plaintiffs,

For: Damages
Monalisa Casupana,
Defendant.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Defendant
Comes Now Defendants, thru and by the undersigned counsel, and to

VVVVV. A statement of their willingness to enter into amicable

Defendant is NOT willing to enter into compromise

agreement because this case was filed by plaintiffs against her
merely for harassment. Plaintiffs have no cause of action against
defendant.
WWWWW. Summary of admitted facts and proposed stipulations of

facts:
Admitted facts:
 A portion of the ground floor of Conti’s Commercial Center
Building located at 2132-2148 Rizal Avenue, East Bajac-Bajac,
Olongapo City was leased by Reynaldo Vergara in 2003;
 A Lease Contract was executed by plaintiff and Reynaldo
Vergara and the same had expired on January 2013;
 Defendant is the Manager of Vercons;
 The receipt of the demand letter of Atty. Nini Cruz;
 Plaintiffs filed two criminal cases of Tresspassing and Unjust

Vexation against the defendant at the Office of the City
Prosecutor in Olongapo City docketed as NPS No. III-10-INV-13-
A-00041 and 00042;
 Both cases were dismissed as per Resolution dated March 25,
2013;
 Defendant made a reply to the demand letter sent by plaintiff
thru counsel Atty. Nini Cruz;
 There is a pending civil case filed by Vercons and Reynaldo
Vergara against plaintiffs at the Regional Trial Court, Branch 75,
Olongapo City, docketed as Civil Case No. 07-0-2013;
 Defendant testified as a witness to the said RTC Case;
 Present during the conference on December 27, 2012 were
defendant, her counsel Atty. Juvy Mell S. Malit, plaintiff, his
wife, Atty. Leonardo Bernabe, Carolle Jane Gingco and another
staff of Mr. Tiu;
 It was a closed door conference and there was no one inside
except the aforesaid persons;
 Carolle Jane O. Gingco is an employee of Limanch-O-Hotel and
Leasing Corporation.
XXXXX. The issues to be resolved:
 Whether or not plaintiffs failed to state cause of action;

 Whether or not the actuations of the defendant in stating that
they did not use the comfort rooms is a valid ground or basis to
award P 100,000.00 damages to plaintiffs;
 Whether or not this case was filed by plaintiffs merely to
harass defendant;
 Whether or not parties are entitled to damages.
YYYYY. Documents to be presented by the plaintiff:
Exhibits Documents
1 Lease Contract between plaintiff and Reynaldo
Vergara and/or RL Vercon Merchants Corporation
2 Complaint in Civil Case No. 07-0-2013

3 Resolution dated March 25, 2013 in IS No. III-10-
INV-13-A-00041 and 42
4 Reply Letter dated December 2, 2014 signed by

Atty. Roniel Dizon Munoz, counsel for Monalisa
Casupanan addressed to Atty. Nini Cruz
5 First Page of the Judicial Affidavit of Carolle Jane

O. Gingco submitted to the RTC Branch 74,
Olongapo City, in the case entitled RL Vercons
Merchant Corporation, Et.Al. vs. Limanch-On Hotel
and Leasing Corporation, Et.Al., docketed as Civil
Case No. 07-0-2013
Defendant reserves the marking of other documents in the course of the

trial.
ZZZZZ. The number and names of the witnesses, the substance of their
witnesses.

Dinalupihan, Bataan, for Olongapo City, 20 January 2015.
Roniel D. Muñoz
Counsel for Defendant
IBP No. 969003, 04/23/2014
PTR No. 2328773, 09/08/2014
Copy furnished:
Atty. Nini D. Cruz
Block 27 Waterdam Roa
Lower Gordon Heights, Olongapo City
Supreme Court
Municipal Trial Court in Cities
Branch 4
Olongapo City
Limanch-O Hotel and Leasing

Corporation and Its President and
General Manager Conrado L. Tiu,
Represented by Carolle Jane O.
Gingco,
Plaintiffs,

For: Damages
Monalisa Casupanan,
Defendant.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Defendant

AAAAAA. A statement of their willingness to enter into amicable

Defendant is not willing to enter into any compromise

agreement with the plaintiff.
BBBBBB. Summary of admitted facts and proposed stipulations of facts:

 Personal circumstances of the parties except that defendant is
married and it has her address at Balsic, Hermosa, Bataan;
 Portion of the ground floor of Conti’s Commercial Center
Building located at 2132-2148 Rizal Ave., East Bajac-Bajac,
Olongapo City was leased by Reynaldo Vergara for the use of
Vercons Supermarket in January 2003;
 Defendant is the Operations Manager of Vercons;
 The Lease Contract between plaintiff and Reynaldo Vergara
expired on roperty subject matter of this case is a parcel of
land situated in Mabiga, Hermosa, Bataan described as Lot
1027-D of the subd. Plan Psd-03-156842 measuring 33,842
square meters;
 Subject property is described in TCT No. T-264011;
 TCT No. T-264011 is registered under the name of Ramon
Navarro and was issued on March 26, 2007;
 TCT No. T-264011 was cancelled by TCT No. 038-2012011086;
 TCT No. T-038-2012011086 is registered under the name of
Luisa Stahl, married to Hans-Juergen Stahl;
 TCT No. T-03820120011086 was issued on October 11, 2012;
 TCT No. T-03820120011086 emanated from TCT No. T-264011;
 Private defendants are not in possession of the subject
property;
 Transfer of the subject property to the private defendants was
by virtue of a Promissory Note (PN) and a Real Estate Mortgage
(REM) dated March 8, 2010;
 Private Defendants do not personally know the plaintiffs at or
about the time that the alleged PN and REM were executed.
They did not meet the plaintiffs;
 Atty. Legaspi neither met the plaintiffs at the alleged execution
of PN and REM;
 Driver’s License No. C02-90-513050 as indicated in the REM to
be the Driver’s License of Ramon Navarro does not belong to
Ramon Navarro;
 The driver’s license of Ramon Navarro bears at that time bears
the number C02-92036695;
 Plaintiffs sent a demand letter to the private defendant prior to
the filing of the instant case;
CCCCCC. The issues to be resolved:

 Whether or not the cancellation of TCT No. T-264011 is valid
and proper;
 Whether or not TCT No. 038-201201186 should be declared
null and void and the reissuance of TCT No. T-264011 should
follow as a consequence;
 Whether or not plaintiffs are entitled to damages by reason of
the acts of the private defendants.
DDDDDD. Documents to be presented by the plaintiff:
Exhibit Documents
A Special Power of Attorney
A-1 Letter to Court dated 10 December 2014
B TCT No. T-264011
C TCT No. T-038-201211086
D Affidavit of Consolidation
E Real Estate Mortgage
F Promissory Note
G Certificate of Sale
H Driver’s License No. C02-92036695
I ID of Ramon Navarro
J Demand Letter
J-1 Registry Receipt
J-2 Return Card
K Medical Certificate of Ramon Navarro
Plaintiffs reserve the marking of other documents in the course of the trial.
EEEEEE. The number and names of the witnesses, the substance of their
witnesses.

Dinalupihan, Bataan, for Olongapo City, 20 January, 2015.
Roniel D. Muñoz
Counsel for Plaintiffs
IBP No. 969003, 04/23/2014
PTR No. 2328773, 09/08/2014
Copy furnished:
Atty. Edmundo Legaspi

Counsel for the Private Defendants
Lot 1 Block 11 National Hi-way
Roosevelt Park Village, San Pablo, Dinalupihan, Bataan
Supreme Court
Dinalupihan-Hermosa
Province of Bataan
Sps. Ramon T. Navarro and Mrs.

Helen E. Navarro represented by
their Atty-in-Fact Liwayway M.
Grumal,
Plaintiff,

For: Annulment and Cancellation
of TCT No. 038-2-12011086 with
Reconveyance of Property and
Damages
Sps. Luisa A. Stahl and Hans

Juergen-Stahl, Et. Al.,
Defendants.
X ----------------- -------------------------------------X
Pre-Trial Brief
for the Plaintiffs
Come Now Plaintiffs, thru and by the undersigned counsel, and to this
Honorable Court, most respectfully submit this Pre-Trial Brief and accordingly
state as follows:
FFFFFF. A statement of their willingness to enter into amicable
Plaintiffs are willing to enter into compromise agreement

that is reasonable and just.
GGGGGG. Summary of admitted facts and proposed stipulations of

facts:
 Plaintiff and defendant Aurea are siblings;

 Defendant Aurea is one of the owners of a property located in
Pinulot, Dinalupihan, Bataan, measuring 240 square meters
and covered by TCT No. 190796;
 Subject property is declared for tax purposes under the name
of Sps. Ricardo and Aurea Fernandez;
 The execution of Real Estate Mortgage by the defendants as
mortgagors dated June 1, 2012;
 The receipt of the demand letters sent by plaintiff to
defendants dated August 4, 2014;
 The referral of the matter to the Office of Barangay Happy
Valley, Dinalupihan, Bataan;
 The payment by the plaintiff of the realty taxes due the subject
property up to the year 2013;
HHHHHH. The issues to be resolved:
 Whether or not plaintiff has cause of action against

defendants;
 Whether or not defendants should execute Deed of Sale of the
subject property in favor of the plaintiff in compliance with the
Real Estate Mortgage they executed on June 1, 2012;
 Who is now the owner of the subject property;
 Whether or not plaintiff is entitled to damages by reason of
the acts of the defendants.
IIIIII. Documents to be presented by the plaintiff:
Exhibit Documents
A TCT No. 190796

B Real Estate Mortgage
C Demand Letter
C-1 Return Card
D Certificate to file action in Court
E Tax Declaration Number 05886
F OR No. 0205287
JJJJJJ. The number and names of the witnesses, the substance of their
witnesses.

Roniel D. Muñoz
IBP No. 969003, 04/23/2014
PTR No. 2328773, 09/08/2014
Copy furnished:
Atty. Edwin C. Torres

Supreme Court
Dinalupihan-Hermosa
Province of Bataan
Shane Edeen Bajada-Caferra,
Plaintiff,
Christopher K. Penaflor,
Defendant.
X-------------------------------------------------------X
Pre-Trial Brief
for the Plaintiff
KKKKKK. A statement of their willingness to enter into amicable

Plaintiff is willing to enter into reasonable compromise

agreement.
LLLLLL. Summary of admitted facts and proposed stipulations of facts:
 Plaintiff and defendant entered into a written contract for the

make-up services on pre-wedding and wedding day of the
plaintiff to her husband;
 Defendant is maintaining a facebook account under the pseudo
name Ginger Penaflor with 2,585 friends as of the filing of the
instant case and 18 of whom are their mutual friends;
 Between July 11, 2014 to July 13, 2014 and July 22, 2014,
defendant posted in his face book regarding his contract with
the plaintiff;
 Parties referred the matter to the Barangay Office of Barangay
General Luna, Dinalupihan, Bataan;
MMMMMM. The issues to be resolved:
 Whether or not plaintiff suffered damages by reason of the

acts of the defendant in posting in his face book rude
comments and post thus causing her sleepless nights,
wounded feelings, besmirched reputation, moral shock, social
humiliation, and the like; and
 Whether or not defendant is liable to plaintiff.
NNNNNN. Documents to be presented by the plaintiffs:
K. Contract executed by the parties on June 27, 2014;

L. Statement of Account, Buma Hotel and Restaurant;
M. Defendant’s FB Profile;
N. July 11 2014 post at FB by Defendant;
O. July 12, 2014 post at FB by Defendant;
P. Second Post on July 12, 2014;
Q. Third Post on July 12, 2014;
R. Fourth Post on July 12, 2014;
S. Barangay Blotter;
T. July 22, 2014 post by defendant in his FB;
U. Receipt for the payment of Catering;
V. Receipt for the payment of Venue; and
W. Judicial Affidavit of plaintiff
Plaintiff reserves the right to mark other documents during

trial.
OOOOOO. The number and names of the witnesses, the substance of

their testimonies, and the approximate number of hours that will be
witnesses.

Dinalupihan, Bataan, September 9, 2014.
Roniel D. Muñoz
Roll No. 63074
PTR No. ____________________
IBP No. 969003, 04/23/2014
MCLE (Exempted)
Copy furnished:
Atty. Sheena E. Bartolome


Supreme Court
National Judicial Region
Metropolitan Trial Court
Branch 65
City of Makati
BDO Unibank, Inc.,

Plaintiff,
Nida C. Padla,
Defendant.
X--------------------------------------------------X
Pre-Trial Brief
for the Defendant
Comes Now Defendant, thru and by the undersigned counsel,

and to this Honorable Court, most respectfully submits this Pre-Trial
PPPPPP. A statement of their willingness to enter into amicable

settlement or alternative modes of dispute resolution, indicating
the desired terms thereof insofar as allowed by law.
Defendant is willing to enter into reasonable

QQQQQQ. Summary of admitted facts and proposed

stipulations of facts:
 Plaintiff is married to Amorsolo Padla, they got married

on May 29, 1985;
RRRRRR. The issues to be resolved:
 Whether or not the instant case should be dismissed for

failure of the plaintiff to implead defendant’s husband;
 Whether or not defendant is liable to plaintiff; and
 Whether or not the amount being collected by the
plaintiff is correct
SSSSSS. Documents to be presented by the plaintiffs:
X. Marriage Contract
Defendant reserves the right to mark other documents

during trial.
TTTTTT. The number and names of the witnesses, the substance of

their testimonies, and the approximate number of hours that will
be required by the parties for the presentation of their respective
witnesses.

substance of their testimony will be supplied at the actual
pre-trial conference proper, with due respect.
Samal, Bataan, August 19, 2014.
Nida C. Padla
Defendant
Sapa, Samal, Bataan
Copy furnished:
Atty. Xerces E. Cortel

Cortel Law Office
Suite 1015, 10th Floor Cityland Condominium 10 Tower I
Ayala Avenue, corner. HV Dela Costa St.,
Makati City
Explanation:
Copies of the foregoing will be served and filed by registered

mail due to the distance involved.
Supreme Court
Branch 5
Dinalupihan, Bataan
Zandrix Del Rosario and

Helki Del Rosario,
Plaintiffs,
Rodante Castro, and all

persons claiming rights over
the subject property,
Defendants.
X--------------------------------------------------X
Pre-Trial Brief
for the Plaintiffs
Come Now Plaintiffs, thru and by the undersigned counsel, and

to this Honorable Court, most respectfully submits this Pre-Trial Brief
and accordingly state as follows:
UUUUUU. A statement of their willingness to enter into

amicable settlement or alternative modes of dispute resolution,
indicating the desired terms thereof insofar as allowed by law.
Plaintiffs are willing to enter into reasonable

VVVVVV. Summary of admitted facts and proposed stipulations of

facts:
 Plaintiffs and defendants are residents of Layac,

Dinalupihan, Bataan;
 Plaintiffs are residing at their father’s (Reynaldo Del
Rosario) house in Layac, Dinalupihan, Bataan, which
property is covered by TCT No. CLOA-4400;
 Defendant constructed a house and store on a public road
in Layac, Dinalupihan, Bataan. As a result, plaintiffs and
all those whose houses are found at the back thereof
could not pass through;
 Such place is a public road as depicted in a
Consolidation of Subdivision Survey made for the DAR
in July 1975;
 Said road was ordered to be maintained as such public
road in a Resolution (Kapasiyahan Blg. 28-96) by the
Office of the Sangguniang Bayan in Dinalupihan,
Bataan;
 A letter protest was filed by the residents of Layac,
Dinalupihan, Bataan to oppose the intention of the
defendant to have said property titled under his name;
 A Memorandum was issued by the DAR stating that the
request of the defendant could not be granted favorable
because the subject road is indispensable and that there
exists a protest;
 The matter was brought to the Office of Barangay Layac,
Dinalupihan, Bataan but was not threshed out;
 The construction of such house and store is a nuisance
that is injurious to the plaintiffs and the public as well;
WWWWWW. The issues to be resolved:
 Whether or not there is valid ground to order the

abatement of all the structures constructed by the
defendant on the subject property;
 Whether or not the subject area is a public road;
 Whether or not the structures are nuisance that are
injurious to the public;
 Whether or not plaintiffs are entitled to damages.
XXXXXX. Documents to be presented by the plaintiffs:
Y. TCT No. CLOA-4400

Z. Pictures
AA. Consolidation of Subdivision Survey
BB. Kapasiyahan No. 28-96
CC. DAR First Indorsement dated March 1, 2001
DD. DAR Memorandum dated March 19, 2001
EE.DAR Letter dated May 30, 2001
FF. MARO First Indorsement dated June 1, 2001
GG. DAR Second Indorsement dated June 4, 2001
HH. DAR Memorandum dated June 11, 2001
II. DAR Third Indorsement dated Sept. 12, 2001
JJ. DAR Fourth Indorsement dated Oct. 16, 2001
KK. DAR Memorandum dated July 3, 2002
LL.Letter of Protest
MM. Memorandum of DAR
NN. Katibayan Upang Makadulog sa Hukuman
Plaintiffs reserve the right to mark other documents

during trial.
YYYYYY. The number and names of the witnesses, the substance of

witnesses.


IBP No. 924014, 01/02/2014
PTR No. 1943598, 01/02/2014
Copy furnished:
Atty. Ildefonso C. Tario

2/F Rueda Bldg., San Jose
Balanga CIty, Bataan

Supreme Court
Branch 5
Dinalupihan, Bataan
Ardee S. Borja,
Petitioner,
Kathryn R. Perez,
Respondent.
X--------------------------------------------------X
Pre-Trial Brief
for the Petitioner
Comes Now Petitioner, thru and by the undersigned counsel,

ZZZZZZ. A statement of their willingness to enter into amicable

It being an annulment case, the above

statement may not be necessary at this time.
AAAAAAA. Summary of admitted facts and proposed

 The existence of a certificate of marriage of the

parties as husband and wife was registered with
the National Statistics Office stating that they
got married on December 21, 2001 in Manila;
 Marriage License No. 181816 as indicated in the
aforesaid Certificate of Marriage belongs to
Jayson Aguinaldo Gando and Jo Ann Alunan
Bereber issued in 2004;
 Marriage License No. 181816 never existed in
2001 when the parties herein allegedly got
married;
 Parties did not cohabit, had no children, and no
properties were acquired under their names;
 There was absence of Marriage License in this
case;
BBBBBBB. The issues to be resolved:

instant petition; or
 Whether or not there was absence of Marriage
License that would warrant the declaration that
the marriage of herein parties is void from the
beginning.
CCCCCCC. Documents to be presented by the petitioner:
OO. Certificate of Marriage

PP. Request for the Celebration of Marriage in a place
other than those authorized by law
QQ. Marriage License No. 181816
RR. Notice for Application of Marriage License
SS. Application for Marriage License of Gando and
Bereber

DDDDDDD. The number and names of the witnesses, the

substance of their testimonies, and the approximate number of
hours that will be required by the parties for the presentation of
their respective witnesses.
The names and address of the witnesses as

well as the substance of their testimony will be
supplied at the actual pre-trial conference proper,
with due respect.

IBP No. 924014, 01/02/2014
PTR No. 1943598, 01/02/2014
Copy furnished:

Balanga, Bataan
Supreme Court
Branch 5
Dinalupihan, Bataan
Ina Clarice Lancin Santiago,

Petitioner,
Louis Soriano Santiago,

Respondent.
X--------------------------------------------------X
Preliminary Conference Brief

for the Respondent
Comes Now Respondent, thru and by the undersigned counsel,

and to this Honorable Court, most respectfully submits this
Preliminary Conference Brief and accordingly states as follows:
EEEEEEE. A statement of their willingness to enter into amicable

Respondent is willing to enter into reasonable

amicable settlement of the instant case with the petitioner
insofar as allowed by law.
FFFFFFF. Summary of admitted facts and proposed stipulations of

facts:
 Parties are married to each other, having been married
since August 4, 2012;
 They have a child named Wilson Clein who was born on
February 2, 2013;
GGGGGGG. The issues to be resolved:
 Whether or not there is valid ground to grant the petition

filed by the petitioner;
 Whether the said petition was filed in accordance with
law; and
 Custody and Support of the child;
HHHHHHH. Documents to be presented by the petitioner:
26 Drug Test Report

27 Medical Certificate
Respondent reserves the right to mark other

IIIIIII. The number and names of the witnesses, the substance of

witnesses.


IBP No. 924014, 01/02/2014
PTR No. 1943598, 01/02/2014
Copy furnished:
Ina Clarice Lancin Santiago

Petitioner
417 Kataasan, Dinalupihan, Bataan
Supreme Court
Branch 51
Guagua, Pampanga
Carlos S. Jimenez, Joined by

His Wife Lalaine Jimenez,
Plaintiff,
- versus – Civil Case No. G-13-4869
Maria Linda Siose, Et.Al.,

Defendants.
X--------------------------------------------------X
Pre-Trial Brief
for the Plaintiff
Comes Now Plaintiff, thru and by the undersigned counsel, and

JJJJJJJ. A statement of their willingness to enter into amicable

the desired terms thereof.

settlement of the instant case with the defendants.
KKKKKKK. Summary of admitted facts and proposed

 Parties knew each other since 2008;
 Defendants were the owners of Mc Lain Motors Phils.,
Inc., a motor shop located in Ayala, Alabang;JJB-104 to
the plaintiff;
 An agreement as to this collateral was executed by the
parties;
 Defendants borrowed the amount of P 500,000.00 from
plaintiff and these were evidenced by two checks issued
by the plaintiff in favor of the defendant;
 Defendant Maria Linda, by way of collateral, gave
possession of One Toyota Rav4 with Plate Number JJB-
104;
 Defendant Maria Linda also issued four (4) checks in
favor of the plaintiff by way of payment and all these
checks were dishonored upon presentment to the bank;
 The motor vehicle given by defendant to plaintiff as
collateral for the loan was taken from the plaintiff by an
employee from the court because according to them it is
the subject of a Writ of Replevin;
 Defendant requested that the payment of her loan be
extended;
 Defendants failed to pay their loan to the plaintiff up to
the filing of the instant case;
 Demand letters were sent to the defendants by the
plaintiff and despite receipt thereof, defendants failed to
pay their loan;
LLLLLLL. The issues to be resolved:
 Whether or not defendants are liable to the plaintiff in

the amount of P 500,000.00 plus all the legal interest
accruing from time of demand;
 Whether or not plaintiff is entitled to damages and
attorney’s fees in bringing this suit.
MMMMMMM. Documents to be presented by the petitioner:
A Metrobank Check No. 0955366

A-1 Metrobank Check No. 0955367
B Agreement
C Banco De Oro Check No. 000458
C-1 Banco De Oro Check No. 000459
D Bank Memo for Exh. C
D-1 Bank Memo for Exh. C-1
E Writ of Replevin
E-1 Order dated April 17, 2009 of RTC Br. 116 Pasay City
E-2 Summons dated April 17, 2009
F Document dated November 9, 2010
G Demand Letter
G-1 Demand Letter
G-2 Demand Letter
Plaintiff reserves the right to mark other documents

during trial.
NNNNNNN. The number and names of the witnesses, the


pre-trial conference, with due respect.
Dinalupihan, Bataan, for Guagua, Pampanga, July 21, 2014.

IBP No. 924014, 01/02/2014
PTR No. 1943598, 01/02/2014
Copy furnished:
Atty. Ulysses L. Gallego

L1, A3, Corinthian Villas, Matimyas St.,
Gen. T. de Leon, Valenzuela City
Supreme Court
Branch 52
Guagua, Pampanga
Dennis S. Malig, Jr., Joined

by His Wife Mylynn P.
Malig,
Vendee-Petitioner,
Moneth M. Malit,
Vendor-Respondent.
X--------------------------------------------------X
Pre-Trial Brief
for the Vendee-Petitioner
Comes Now Vendee-Petitioner, thru and by the undersigned

counsel, and to this Honorable Court, most respectfully submits this
Pre-Trial Brief and accordingly states as follows:
OOOOOOO. A summary of admitted facts and proposed

 Existence and due execution of Deed of Sale with

Pacto De Retro dated March 11, 2013 executed by
the parties herein;
 TCT No. 042-705911-R is registered under the
name of the vendor-respondent and the original
thereof is in the custody of the vendee-petitioner;
 Vendor-respondent mortgaged the property
covered by the subject title first to Lucila
Pungyan;
 She was not able to pay the loan to Lucila
Pungyan;
 Lucila Pungyan is the mother of vendee-
petitioner’s wife;
 Vendor-respondent first submitted a fake title
(705911-R) to Lucila Pungyan;
 Which title was confiscated by the Registry of
Deeds for being fake and spurious;
PPPPPPP. The issues to be resolved:
 Whether or not there is valid ground to order the

consolidation of ownership in favor of vendee a retro
under the Civil Code;
 Whether or not vendee-petitioner is entitled to
damages
QQQQQQQ. Documents to be presented by the petitioner:
 Deed of Sale under pacto de retro dated March 11, 2013

 TCT No. 042-705911-R
 Real Estate Mortgage
 TCT No. 705911-R (fake)
 Letter of RD dated December 16, 2011 to Moneth Malit
Vendee-Petitioner reserves the right to mark other

RRRRRRR. The number and names of the witnesses, the


actual pre-trial conference, with due respect.
Dinalupihan, Bataan, for Guagua, Pampanga, December 9, 2013.

Counsel for the Vendee-Petitioner
IBP No. 837850, 01/02/2013
PTR No. 1450932, 01/03/2013
MCLE Compliance No. IV-0006775, 07/16/2012
Copy furnished:
Atty. Eigee V. Galacgac

Counsel for the Vendor-Respondent
OIC, Public Attorney III
Plates and Platter Compound
Olongapo-Gapan Road
San Matias, Guagua, Pampanga
Supreme Court
Branch 5
Dinalupihan, Bataan
Enrique G. Dabu,
Plaintiff,

Raquel G. Eslava,
Defendant.
X--------------------------------------------------X
Pre-Trial Brief
for the Plaintiff

SSSSSSS. A summary of admitted facts and proposed stipulations of

facts:
 Plaintiff is the owner of Arber Rice Mill;

 Defendant purchased on credit several bags of
rice from plaintiff amounting to P 637,000.00;
 Parties executed an agreement denominated as
“Kasunduan” on December 22, 2010;
 Defendant only paid P 25,000.00;
 Defendant did not faithfully comply with the
said Kasunduan;
 Plaintiff sent demand letter to defendant
demanding for the payment of P 612,000.00 and
said demand letter was received by the
defendant;
 Despite receipt thereof, defendant did not pay
her obligation to the plaintiff
TTTTTTT. The issues to be resolved:
 Whether or not there defendant is liable to pay her

obligation of P 612,000.00 to the plaintiff;
 Whether or not plaintiff is entitled to damages
UUUUUUU. Documents to be presented by the petitioner:
 Kasunduan executed on December 22, 2010

 Demand Letter
 Return Card
Petitioner reserves the right to mark other documents

during trial.
VVVVVVV. The number and names of the witnesses, the



IBP No. 837850, 01/02/2013
PTR No. 1450932, 01/03/2013
Copy furnished:
Atty. Edwin Torres


Supreme Court
Branch 5
Dinalupihan, Bataan
Rodel B. Bungay,
Petitioner,
Jennelyn F. Bungay,
Respondent.
X--------------------------------------------------X
Pre-Trial Brief
for the Respondent
Comes Now Respondent, thru and by the undersigned counsel,

WWWWWWW.A statement of willingness to enter into amicable

the desired terms thereof:
Respondent is willing to enter into amicable

settlement of the case provided that the proposal is
reasonable and acceptable taking into consideration
the benefit and interest of the parties’ children.
XXXXXXX. A summary of admitted facts and proposed

 Fact of marriage;
 Births of their children;
 Fact of separation;
 That the petitioner is no longer residing in their
conjugal dwelling;
 That all of their children have been in the
custody of their mother, who is the respondent
in this case;
 That there was no support coming from the
petitioner for the longest time;
 That there was earnest effort to settle their
differences but to no avail; and the
 Properties and Liabilities involved
YYYYYYY. The issues to be resolved:
 Whether or not respondent and their children are

entitled to support pendent lite in the amount of P
25,000.00 a month;
 To whom should the net of the properties be awarded;
and
 The custody of their children
ZZZZZZZ. Documents to be presented by respondent:
Having the same sets of documents as the petitioner,

respondent will adopt the documentary evidence to be
requested to be marked by the petitioner with reservation
to mark other documents during pre-trial.
AAAAAAAA. The number and names of the witnesses, the


Dinalupihan, Bataan, November 11, 2013.

IBP No. 837850, 01/02/2013
PTR No. 1450932, 01/03/2013
Copy furnished:
Atty. Juliet S. Salaria
3rd Floor Chowking Bldg.,

Supreme Court
Third Judicial Regiona
Dinalupihan-Hermosa
Province of Bataan
Diana May P. Reyes,

Complainant,

For: Damages
Jane Dominguez,
Defendant.
X--------------------------------------------------X
Pre-Trial Brief
for the Complainant

BBBBBBBB. A statement of willingness to enter into amicable

the desired terms thereof:
Plaintiff is willing to enter into amicable

settlement of the case provided that the proposal is
reasonable and acceptable to the plaintiff taking
into consideration the damages she has suffered by
reason of the acts of the defendant that led into the
filing of this case.
CCCCCCCC. A summary of admitted facts and proposed

 That the posts indicated in the complaint were

made by the defendant;
 That it was the defendant who first made a
comment on the picture posted in the face book
account of Joana Marie Punzalan;
DDDDDDDD. The issues to be resolved:

 Whether or not defendant should be held liable for
damages to plaintiff for posts made on the face book;
 Whether or not such posted comments made by
defendants are contrary to morals, good customs;
 Whether or not plaintiff suffered damages.
EEEEEEEE. Documents to be presented by plaintiff:
A - Profile facebook account of plaintiff

B - Picture posted on July 11, 2013
C - Demand Letter dated July 13, 2013
Plaintiff reserves to mark such other available

documents that may be needed during the course of
the trial.
FFFFFFFF.The number and names of the witnesses, the substance of

witnesses.

Dinalupihan, Bataan, October 22, 2013.

IBP No. 837850, 01/02/2013
PTR No. 1450932, 01/03/2013
Copy furnished:
Ms. Jane Dominguez

Defendant
Sta. Lucia, Samal, Bataan

Supreme Court
Branch 49
Guagua, Pampanga
Carlos Jimenez, Joined By

His wife Lalaine Jimenez,
Plaintiff,

For: Collection of Sum of Money
and Damages
Noe A. Tanjuakio,
Defendant.
X--------------------------------------------------X
Pre-Trial Brief
for the Plaintiff
Comes Now Plaintiff, thru the undersigned counsel, and to this

GGGGGGGG. Statement of parties willingness to enter into

indicating the desired terms thereof:
Plaintiff is willing to enter into compromise

agreement with the defendant provided that the terms
are reasonable.
HHHHHHHH. A summary of admitted facts and propose stipulation

of facts:
Proposal for stipulation of facts:
 The personal circumstances of the parties;

 Defendant borrowed the amount of P 450,000.00
from plaintiff sometime in the year 2003;
 Defendant paid P 54,000,00 annually starting in
the year 2003 up to 2007 as annual interest on the
amount loaned from plaintiff;
 A demand letter was sent by plaintiff to
defendant demanding payment of the loan;
 Defendant received said demand letter, and in
fact he replied said letter thru his lawyer Atty.
Ildebrando D. Viernesto;
IIIIIIII. The issues to be tried or resolved:
 Whether or not defendant should be ordered to

pay the loan he obtained from plaintiff;
 Whether or not plaintiff is entitled to damages;
JJJJJJJJ. Manifestation of their having availed or their intention to

avail themselves of discovery procedure or referral to
commissioners:
As of this writing, plaintiff has no intention

of availing the discovery procedure or referral to
commissioners.
KKKKKKKK. Documents to be presented:
Exh. Documents
A Deed of Sale of shares of stocks

B Letter sent by plaintiff to defendant on October
31, 2004
C Demand letter
C-1 Return Card
D Reply Letter of Atty. Viernesto
Plaintiff reserves to mark such other

available documents that may be needed during the
course of the trial.
LLLLLLLL. The number and names of the witnesses, the substance of

witnesses.

Dinalupihan, Bataan, for Guagua, Pampanga, August 27, 2013 .

IBP No. 837850, 01/02/2013
PTR No. 1450932, 01/03/2013
Copy furnished:
Atty. Ildebrando D. Viernesto

Unit 20 Casa Nueva Manila
Manga Road, New Manila
Quezon City, 1112
Supreme Court
Branch 74
Olongapo City
RL Vercons Merchants
Corporation, Et.Al.,
Plaintiffs,
- versus – Civil Case No. 07-0-13

For: Specific Performance and
Damages
Limanch O. Hotel, Et.Al.,

Defendants.
X--------------------------------------------------X
Pre-Trial Brief
for the Plaintiffs
Come Now Plaintiffs, thru the undersigned counsel, and to this

Honorable Court, most respectfully submit this Pre-Trial Brief and
MMMMMMMM. Statement of parties willingness to enter into

Plaintiffs are willing to enter into compromise

agreement provided that the terms are reasonable with
the defendants.
NNNNNNNN. A summary of admitted facts and propose stipulation

of facts:

 The existence of the Contract of Lease entered
into on January 9, 2003 of parties herein;
 The payment by plaintiffs to defendants of the
amount of P 5,659,074.48 as security deposit;
 The purchase by the plaintiffs of the old
freezers, chiller, furniture, telephone units,
scales, conveyors and all items belonging to and
all things related to the use in operating a
supermarket in the amount of P8,000,000.00 paid
to defendants;
 The payment of P 17,000,000.00 by plaintiffs to
defendants for the unsold groceries of Conti-J;
 Meeting on December 27, 2012 in the presence of
Atty. Bernabe, Atty Malit, defendant Tiu and
wife, two staffs of Mr. Tiu;
 The building involved in this case was built
more than 38 years ago;
 Repairs were introduced by plaintiffs prior to
the turnover of the premises to the defendants;
 Defendants filed a criminal case against
Monaliza Casupanan, Manager of the plaintiffs,
and the same was dismissed by the Office of the
City Prosecutor, Olongapo City;
 On January 8, 2013, the premises involved in this
case were turned over to the defendants;
 Plaintiffs sent defendants demand letter for the
return of the amount of P 5,659,074.48 as security
deposit.
OOOOOOOO. The issues to be tried or resolved:
 Whether or not defendants should be ordered to

return the amount of P 5,659,074.48 to the
plaintiffs which the latter paid by way of
security deposit (less the unpaid electricity bill
of P 18,786.13;
 Whether or not plaintiffs are entitled to damages;
PPPPPPPP. Manifestation of their having availed or their
intention to avail themselves of discovery procedure or referral
to commissioners:
As of this writing, plaintiffs have no intention

of availing the discovery procedure or referral to
commissioners.
QQQQQQQQ. Documents to be presented:
Exh. Documents
A Certificate of Incorporation of RL Merchants

B Board Resolution a
B-1 Secretary’s Certificate
C Lease Contract
D Evidence of payment for the P 8M
E Sample Letters of defendants to plaintiffs
F Letter dated December 26, 2012 of defendants to
Plaintiffs
F-1 Reply of plaintiffs to Exh. “F”
G Pictures not acceptable to defendants
H Pictures before and after repairs
I Summary of Expenses
J Letter to turn-over premises
K Demand Letter
K-1 Letter of defendant dated January 8, 2013
L Letter dated January 10, 2013
M Letter dated February 23, 2012
N Letter of Mr. Tiu dated January 15, 2012
N-1 Reply letter to Exh. “N”
O Demand Letter dated January 21, 2013
Plaintiffs reserve to mark such other available

documents that may be needed during the course of
the trial.
RRRRRRRR. The number and names of the witnesses, the


Dinalupihan, Bataan, for Olongapo City, July 30, 2013.

IBP No. 837850, 01/02/2013
PTR No. 1450932, 01/03/2013
Copy furnished:
Atty. Leonardo W. Bernabe

GT Solar Bldg., Sta. Rita corner Canal Roads
CBD, Subic Bay Freeport Zone
Olongapo City
Supreme Court
Dinalupihan-Hermosa
Province of Bataan
Rachelle M. Bautista,
Plaintiff,
Raymond De Guzman Gervacio,

Defendant.
X-----------------------------------------------------------X
Pre-Trial Brief
for the Plaintiff
Comes Now Plaintiff, thru the undersigned counsel, and to this Honorable
Court, most respectfully submits this Pre-Trial Brief and accordingly states as
follows:
SSSSSSSS. Statement of parties willingness to enter into amicable

settlement or alternative modes of dispute resolution, indicating the desired
terms thereof:
Plaintiff is willing to enter into reasonable compromise agreement with the

defendant.
TTTTTTTT. A summary of admitted facts and propose stipulation of facts:

 Defendant is the brother of Rafael Gervacio;
 Rafael Gervacio was formerly the boyfriend of plaintiff;
 Defendant and plaintiff are facebook friends prior to the filing of the
instant case;
 Defendant posted the following to plaintiff’s facebook account on June 10,
2012:
Raymond De Guzman Gervacio rachelle Mercado bautista-are u
insane? U better fix your life rather than to destroy our dignity and
reputation..look, cnu ngaun ung nagmumukhang katawa tawa? U know, my
pinag-aralan aq, pro below d belt kana.. don’t accused us. Lhat ng cnsv mu foul,
story teller ka din plan uh..! wag n wag mung idadamay family ko sa kahibangan
at kabaliwan mu..kahit san tau umabot, ndi kme aatras, ibang klase ka din e
nuh..ure so pathetic, gusto mu isa isahin q qng cnu ka?ikaw lng nman ung
nkikiapid s my asawa ng my asawa, u sell urself just to have money.see who’s
beggar and desperate??. Ipagpatuloy mu lng yan ng dumame pa mging atrsao mo.
U should know ur limitations...magkita nlang tau sa barangay, be ready
mgkakaharap harap din tau.!!!
UUUUUUUU. The issues to be tried or resolved:
 Whether or not plaintiff is entitled to damages;

 Whether or not defendant is liable to pay plaintiff with damages;
VVVVVVVV. Manifestation of their having availed or their intention to avail

themselves of discovery procedure or referral to commissioners:
As of this writing, plaintiff has no intention of availing the discovery
procedure or referral to commissioners.
WWWWWWWW. Documents to be presented:
Exh. Documents Purpose
A Facebook Entry for

Plaintiff To prove that plaintiff is the holder of
facebook account under the name
rachellebirney@yahoo.com and has 219 friends
prior to the filing of this case.
B Comment of Defendant
To Plaintiff’s Face Book
Account To prove that defendant made the following
comment to plaintiff’s facebook account that
resulted to injury and damages.
C Brgy. Certificate
To prove that the matter was brought to the
office of Brgy. Saguing, Dinalupihan, Bataan.
Plaintiff reserves to mark such other available documents that may be

needed during the course of the trial.
XXXXXXXX. The number and names of the witnesses, the substance of their
testimonies, and the approximate number of hours that will be required by
the parties for the presentation of their respective witnesses.
The names and address of the witnesses as well as the substance of their
testimony will be supplied at the actual pre-trial conference, with due respect.

IBP No. 837850, 01/02/2013
PTR No. 1450932, 01/03/2013
Copy furnished:
Atty. Dante G. Ilaya
Ilaya Law Office
Supreme Court
Dinalupihan-Hermosa
Province of Bataan
Mary Anne Diuco, joined by her

husband Daniel D. Diuco,
Plaintiff,

For: Collection of Sum of
money and damages
Julie Dimacali, joined by her

husband Jaime Dimacali,
Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
Pre-Trial Brief
for the Plaintiffs
Honorable Court, most respectfully submits this Pre-Trial Brief and accordingly
states as follows:
YYYYYYYY. Statement of parties willingness to enter into amicable

terms thereof:
Plaintiff is willing to enter into amicable settlement

with the defendant provided that the same is reasonable.
ZZZZZZZZ. A summary of admitted facts and propose stipulation of facts:
i.) Defendant borrowed the amount of P 100,000.00 from

plaintiff on April 18, 2012;
ii.) Said loan is not yet fully paid;

iii.) Plaintiff sent defendant several demand letters to
collect said loan and interest;
iv.) The matter was brought to the Office of Barangay New

San Jose Dinalupihan, Bataan.
AAAAAAAAA. The issues to be tried or resolved:
i.) Whether or not defendant is liable to plaintiff and how

much?
ii.) Whether or not parties are liable for damages.
BBBBBBBBB. Documents to be presented:
A – Loan document
B – Demand Letter dated August 31, 2012
B-1- Return Card
C- Certificate to file case in Court
CCCCCCCCC. Manifestation of their having availed or their intention to avail

Plaintiff has no intention yet of availing the discovery
procedure or referring the matter to commissioners.
DDDDDDDDD. The number and names of the witnesses, the substance of their
Witness for the plaintiff and substance of testimonies

will be made during the preliminary conference.

Sta. Isabel Dinalupihan, Bataan
PTR No. 0947792, 01/02/2012
IBP No. 837794, 01/02/2012
Bataan
Copy furnished:
Atty. Sheena E. Esteban

Counsel for Defendants
Public Attorney’s Office (PAO)
New Justice Hall Building
Dinalupihan, Bataan
Supreme Court
Branch 72
Olongapo City
Sps. Engr. Benjamin and Dolores

Escobar,
Plaintiffs,
- versus – Civil Case No. 32-0-2011
Jose Alejandre Payumo III,

Defendant.
X-----------------------------------------------------------X
Pre-Trial Brief for the Defendant
Comes Now Defendant, thru the undersigned counsel, and to this

Honorable Court, most respectfully submits this Pre-Trial Brief in compliance with
the Order dated September 5, 2011 and accordingly states as follows:
EEEEEEEEE. Statement of parties willingness to enter into amicable
terms thereof:
The above named defendant is willing to enter into reasonable compromise

agreement with the plaintiffs as may be reasonable and allowed by law.
FFFFFFFFF. A summary of admitted facts and propose stipulation of facts:
 None
GGGGGGGGG. The issues to be tried or resolved:
 Whether or not plaintiffs have cause of action against herein named

defendant;
 Whether or not parties are liable for damages;
HHHHHHHHH. Manifestation of their having availed or their intention to avail

As of this writing, defendant has no intention of availing the discovery
IIIIIIIII. The number and names of the witnesses, the substance of their
Dinalupihan, Bataan, for Olongapo City, September 16, 2011.

2nd Floor JAKA Bldg.,
Bonifacio St., Dinalupihan, Bataan
IBP No. 662038, 01/03/2011
PTR No. 0506906, 01/04/2011
MCLE Compliance No. III-0011723
Copy furnished:
Atty. Oscar L. Karaan

Karaan and Karaan Law Office
Rm. 410 Roman Santos Bldg.,
Plaza Lacson, Sta. Cruz, Manila

Supreme Court
Branch 2
Margie O. Singian-Samia,
Petitioner,
Allan S. Samia,
Respondent.
X-----------------------------------------------------------X
Petitioner’s
Pre-Trial Brief
Comes Now Petitioner, thru the undersigned counsel, and to this

Honorable Court, most respectfully submits this Pre-Trial Brief and accordingly
states as follows:
JJJJJJJJJ. Statement of parties willingness to enter into amicable settlement or

thereof:

agreement with the respondent in as far as it is allowed by law
and provided that it be reasonable and justifiable.
KKKKKKKKK. A summary of admitted facts and propose stipulation of facts:
Proposed Stipulation of Facts2
 Fact of Marriage of Parties

 Fact of Birth of Parties’ child named Aldwin S. Samia;
 The child has been in the custody of the petitioner; and
 Parties did not acquire properties during their consortium;
 Petitioner underwent psychological evaluation/test
LLLLLLLLL. The issues to be tried or resolved:
 Whether or not parties’ marriage is a nullity or could be

declared as null and void pursuant to Art. 36 of the Family
Code of the Philippines

child
MMMMMMMMM. Documents to be presented:
Petitioner intends to present the following documents:
2
Respondent did not file his Answer in this case.
 Marriage Contract of the Parties;
 Birth Certificate of Aldwin S. Samia;
 Psychological Evaluation Report of Ruben Leo Manrique
 Judicial Affidavit of Petitioner
 Judicial Affidavit of Ruben Leo Manrique
Petitioner reserves the right to present additional evidence

during the course of the trial.
Dinalupihan, Bataan, for Balanga City, October 7, 2010.

IBP No. 661990, 01/04/2010
PTR No. 0087381, 01/04/2010
Bataan
Copies furnished:
Mr. Allan S. Samia

Respondent
Kalye Bulag, Calapacuan
Subic, Zambales

RGS Bldg., C
Supreme Court
Branch 2
Maebelle A. Ronquillo,
Petitioner,
Randy O. Ronquillo,
Respondent.
X-----------------------------------------------------------X
Petitioner’s
Pre-Trial Brief

Honorable Court, most respectfully submits this Pre-Trial Brief in compliance with
the Notice of Pre-Trial Conference dated September 29, 2010, and accordingly
states as follows:
NNNNNNNNN. Statement of parties willingness to enter into amicable

terms thereof:

agreement with the respondent in as far as it is allowed by law
and provided that it be reasonable and justifiable.
OOOOOOOOO. A summary of admitted facts and propose stipulation of facts:
Admitted Facts3
 Paragraphs 1, 2, 3, 4, 5 and 11 of the Petition and these

include the fact of marriage of the parties, the fact of birth
of their child, and the acquisition of real property in 2004;
 Parties are already separated even before the filing of the

instant case
 Petitioner is providing their child with financial support
PPPPPPPPP. The issues to be tried or resolved:
 Whether or not parties marriage is a nullity or could be

declared as null and void pursuant to Art. 36 of the Family
Code of the Philippines
 Settlement of the property acquired by the parties; and

3
As per Defendant’s Answer dated July 12, 2010.
child
QQQQQQQQQ. Documents to be presented:
Petitioner intends to present the following documents:
 Psychological Evaluation Report of Ruben Leo Manrique
Petitioner reserves the right to present additional evidence

during the course of the trial.
Dinalupihan, Bataan, for Balanga City, August 19, 2010.

IBP No. 661990, 01/04/2010
PTR No. 0087381, 01/04/2010
Bataan
Copy furnished:
Atty. Flaviano T. Aguanta

RGS Bldg.apitol Drive
Balanga City, Bataan.Republic of the Philippines
Supreme Court
Municipal Trial Court of Lubao
Province of Pampanga
Sps. Ernesto Jimenez and Margie

N. Jimenez,
Plaintiffs,

Susana Limpim Velasco,
Defendant.
X--------------------------------------------------------X
Pre-Trial Brief
for the Plaintiffs
Come Now Plaintiffs, thru the undersigned counsel, and to this Honorable
Court, most respectfully submit this Pre-Trial Brief and accordingly state as
follows:
RRRRRRRRR. Statement of parties willingness to enter into amicable

terms thereof:
Plaintiffs are willing to enter into reasonable compromise

agreement with the defendant as may be allowed by law.
SSSSSSSSS. A summary of admitted facts and propose stipulation of facts:
* That the checks involved in this case were issued by the

defendant;
* That defendant knew plaintiffs;
TTTTTTTTT. The issues to be tried or resolved:
 Whether or not defendant is indebted to the plaintiffs;

UUUUUUUUU. Documents to be presented:
As Exh. A is copy of BPI Check No. 0108459 dated January 31, 2007 in
the amount of P 76,000.00;
As Exh. A-1 is copy of BPI Check No. 0108464 dated February 16,
2007 in the amount of P 99,000.00;
As Exh. B is copy of the demand letter dated March 4, 2010
Plaintiffs reserve the right to present evidence during the

VVVVVVVVV. Manifestation of their having availed or their intention to avail
As of this writing, plaintiffs have no intention of

availing the discovery procedure or referral to commissioners.
WWWWWWWWW. The number and names of the witnesses, the substance

of their testimonies, and the approximate number of hours that will be
required by the parties for the presentation of their respective witnesses.

substance of their testimony will be supplied at the actual pre-
trial conference, with due respect.
Dinalupihan, Bataan, for Lubao, Pampanga, October 6, 2010.

IBP No. 661990, 01/04/2010
PTR No. 0087381, 01/04/2010
Bataan
MCLE Compliance No. III-0011723, 04/12/2010
Copy furnished:
Atty. Victor B. Roque
Counsel for Defendant
Immaculate Concepcion St.
Dolores Homesite Ext. II, Dolores
City of San Fernando, Pampanga
Plaintiff
Unit 1210 Makati Cinema Square Tower
Pasong Tamo St., Makati City
Supreme Court
Branch 1
Jeffrey Ocampo,
Petitioner,
Karen M. Ocapo,
Respondent.
X-------------------------------------------------X
Petitioner’s
Pre-Trial Brief

Honorable Court, most respectfully submits this Pre-Trial Brief in
compliance with the Notice dated August 3, and accordingly states as
follows:
XXXXXXXXX. Statement of parties willingness to enter into

Petitioner is willing to enter into reasonable

compromise agreement with the respondent in as far as
it is allowed by law and provided that it be reasonable
and justifiable.
YYYYYYYYY. A summary of admitted facts and propose stipulation

of facts:
Admitted Facts4
 Paragraphs 1, 2, 3, 4, 5 and 11 of the Petition and

these include the fact of marriage of the parties,
the fact of birth of their child, and the acquisition
of real property in 2004;
 Parties are already separated even before the filing

of the instant case
 Petitioner is providing their child with financial

support
ZZZZZZZZZ. The issues to be tried or resolved:
 Whether or not parties marriage is a nullity or

could be declared as null and void pursuant to
Art. 36 of the Family Code of the Philippines
4
 Settlement of the property acquired by the parties;
and
 Custody and/or visitorial rights of the parties

over their child
AAAAAAAAAA. Documents to be presented:

documents:

Manrique

Dinalupihan, Bataan, for Balanga City, August 19, 2010.

IBP No. 661990, 01/04/2010
PTR No. 0087381, 01/04/2010
Bataan
Copy furnished:
Atty. Flaviano T. Aguanta

RGS Bldg., Capitol Drive
Balanga City, Bataan.
Supreme Court
Branch 1
Oscar P. Dungan, Et.Al.,

Plaintiff,
Reynaldo Robles, Et.Al.,

Defendants.
X-------------------------------------------------X
Plaintiff’s
Pre-Trial Brief

Honorable Court, most respectfully submits this Pre-Trial Brief in
compliance with the Notice dated August 3, and accordingly states as
follows:
BBBBBBBBBB. Statement of parties willingness to enter into

Plaintiff is willing to enter into reasonable

compromise agreement with the defendants.
CCCCCCCCCC. A summary of admitted facts and propose stipulation

of facts:
Admitted Facts5
 TCT No. T-227626 registered in the name of

defendant Robles was again cancelled by TCT No.
038-20100000107 in favor of defendant Bautista. A
5
Deed of Absolute Sale executed by defendant
Robles as vendor in favor of defendant Bautista as
vendee was executed on December 7, 2009;
 At present, defendant Bautista is possessing the

subject property;
 Prior to the filing of the instant case, plaintiff

consulted his counsel. His counsel suggested that
both defendants be invited for a conference for a
possibility of setting the matter out of court. An
invitation letter was sent to defendants setting the
conference on February 15, 2010. Both defendants
acceded and appeared at the office of the
undersigned counsel on said date;
 There was another meeting held thereafter. Parties

did not agree, thus the filing of the instant case.
 The existence of two Deeds of Sale on the subject

property. First the alleged Deed of Sale between
plaintiff and defendant Robles and second, the
alleged Deed of Sale between defendant Robles
and defendant Bautista;
DDDDDDDDDD.The issues to be tried or resolved:
 Who is the owner of the property subject matter of

this case;
 Whether or not the two Deeds of Sale are valid;
 Whether or not parties are entitled to damages by
reason of the malevolent acts of the defendants
EEEEEEEEEE. Documents to be presented:
Plaintiff intends to present the following

documents:
 TCT No. T-124826;
 TCT No. T-227626;
 Deed of Sale allegedly executed on November 19,
2002;
 Passport of the plaintiff;
 TCT No. 038-20100000107;
 Certification issued by the Municipal Treasurer of
Orion, Bataan; and
 Invitation Letter
Plaintiff reserves the right to present additional


IBP No. 661990, 01/04/2010
PTR No. 0087381, 01/04/2010
Bataan
Copy furnished:
Atty. Marilet Santos Layug

Counsel for Defendant Robles
Rm. 6 Naval Commercial Center
Balanga, City, Bataan
Supreme Court
Branch 41
Heirs of Ines Lagman: Namely:

Rafael Lagman, Et.Al.,
Petitioners,
Heirs of Bernie Dizon:

Namely, Maria S. Dizon,
Et.Al.,
Respondents.
X-----------------------------------------------------X
Pre-Trial Brief
For The Petitioners
Come Now Petitioners, thru the undersigned counsel, and to this

Honorable Court, most respectfully submit this Pre-Trial Brief, and accordingly
state as follows:
A. Statement of willingness to enter into an amicable settlement indicating the
desired terms thereof or to submit the case to any of the alternative modes
of dispute resolution:
Petitioners are willing to enter into reasonable compromise agreement

with the respondents.
B. Summary of admitted fact and propose stipulation of facts:
Admitted facts:
a. The personal circumstances of the respondents;

b. The existence of Katibayan ng Orihinal ng Titulo Blg. 11717 issued to Maria
Dizon, married to Bernie Dizon on November 3, 2004;
c. The Filing of a petition for cancellation of the subject title before the
Department of Environment and Natural Resources (DENR), Regional Office
No. III, City of San Fernando, Pampanga;
d. The fact that an investigation was conducted by the DENR in connection with
the case filed before them;
e. The existence and due execution of the Decision dated November 24, 2009
C. The issues to be tried or resolved:
a. Whether or not petitioners have legal cause of action against the

respondents?
b. Whether or not there is legal ground or basis for the cancellation of TCT
No. 11717;
c. Who is the owner or owners of the subject property or who has the
better right to possess/occupy the subject property;
d. Whether or not a new title should be issued in favor of the petitioners
after the cancellation of the title subject matter of this case which was
fraudulently title in the name of Maria Dizon;
e. Whether or not parties are entitled to damages.
D. The documents or exhibits to be presented, stating the purpose thereof:
Documents Purpose (s)
Special Power of Attorney

To prove that the representatives of the
petitioners herein are duly armed with
Special Powers of Attorney.
Decision Adjudicanto Lotes No.

Convenrtidos issued by Juzgado
De Primera Instancia
To prove that subject property was originally
awarded to Gonzalo Taruc.
Deed of Absolute Sale executed

by Gonzalo Taruc and Catalina
Dizon to Fructoso Dimacali
(married to Carmen Sambile)
To prove that Gonzalo Taruc sold the subject
property to Fructoso Dimacali on November
27, 1961.
Decision in Cad. Case No. 53,
LRC Cad Rec No. 1973 on Lot
NO. 1458 issued by the 5 th
Judicial District First Branch,
Pampanga entitled Director of
Lands vs. Spouses Fructoso
Dimacali and Carmen Sambile
dated March 12, 1962
To confirm the title to Lot 1458 in favor of
Spouses Dimacali as their conjugal property.
Deed of Sale executed by
Spouses Dimacali in favor of
Martin S. Lagman, Maxima S.
Lagman, Juliana S. Lagman,
Celedino S. Lagman and Ines
Lagman
To prove that Spouses Dimacali sold the subject
property to Martin S. Lagman, Maxima S. Lagman,
Juliana S. Lagman, Celedino S. Lagman and Ines
Lagman on April 28, 1980.
Declaration of Real Property

To prove that subject property has been
declared for tax purposes in the name of
Fructoso Dimacali.
Official Receipts of payment of

Realty Taxes
To prove exercise of ownership and to prove
that realty taxes are religiously paid by the
petitioners.
Several documents used in
fraudulently having the subject
title issued in the name of Maria
Dizon
To prove that the subject title has been
fraudulently issued in the name of Maria
Dizon.
Katibayan ng Original na Titulo
Blg. 11717
To prove existence of the same title.
Pictures
To prove actual occupation by the petitioners
of the subject title. To prove that
improvement have been introduced by the
petitioners.
Pictures of Lot 1459

To prove the correct lot being possessed by
the respondents.
Decision of the DENR dated

November 24, 2009
To prove that a Decision was issued by the
DENR on November 24, 2009 in the protest
filed by the same petitioners herein
sustaining the same protest and directing the
filing of the instant case before the regular
court.
Petitioners reserve the right to present other documents as the need arises and as
trial progresses.
E. Manifestation of their having availed or their intention to avail themselves

of discovery procedure or referral to commissioners:
As of this writing, petitioners have no intention to avail of the discovery
F. The number and names of the witnesses, the substance of their testimonies,
and the approximate number of hours that will be required by the parties
for the presentation of their respective witnesses.
Petitioners will supply the names and address of the witnesses on the scheduled
pre-trial conference because it will depend on the admission to be made by the
respondents.
Dinalupihan, Bataan, for the City of San Fernando, Pampanga, April 14,
2010.

Counsel for the Petitioners
IBP No. 661990, 01/04/2010
PTR No. 0087381, 01/04/2010
Bataan
Copy furnished:
Atty. Restituto David

Counsel for the Respondents
DSF Bldg., Gen. Hizon Ave.,
Supreme Court
Metropolitan Trial Court
Pasay City, Metro Manila
Branch XLV (45)
Argus Credit Corporation,

Plaintiff,
- versus – Civil Case No. M-PSY-10-10747-CV

For: Replevin and/or Sum of Money with
Damages
Rowena C. Manabat, Et.Al.,

Defendants.
X-----------------------------------------------------------X
Pre-Trial Brief for the Defendants
Come Now Defendants Spouses Jose and Rowena Manabat, thru the
undersigned counsel, and to this Honorable Court, most respectfully submit this
Pre-Trial Brief in compliance with the Order dated March 2, 2010 (received on
March 9, 2010) and accordingly state as follows:
FFFFFFFFFF. Statement of parties willingness to enter into amicable
terms thereof:
The above named defendants are willing to enter into reasonable compromise
agreement with the plaintiff as may be allowed by law.
GGGGGGGGGG. A summary of admitted facts and propose stipulation

of facts:
 That plaintiff is not duly represented in this case;

 That the loan mentioned in paragraph 9 of the complaint has been fully
settled by herein named defendants;
HHHHHHHHHH. The issues to be tried or resolved:
 Whether or not plaintiff has cause of action against herein named

defendants;
IIIIIIIIII. Documents to be presented:
Defendants named herein intend to present the following:
 Letter of Atty. Antonio C. Silang dated December 22, 2009

 Statement of Account
 Secretary’s Certificate of the Plaintiff
Defendants reserve the right to present additional evidence during the

JJJJJJJJJJ. Manifestation of their having availed or their intention to avail

As of this writing, defendants have no intention of availing the
discovery procedure or referral to commissioners.
KKKKKKKKKK. The number and names of the witnesses, the substance of their
Dinalupihan, Bataan, for Pasay City, 15 March, 2010.

Counsel for the Defendants Manabat
IBP No. 661990, 01/04/2010
PTR No. 0087381, 01/04/2010
Bataan
MCLE Compliance No. I-0013723
MCLE Compliance No. II-0005961
Copy furnished:
Atty. Antonio C. Silang

1052 MPI Building, EDSA
Magallanes Village, Makati City
Supreme Court
OF DINALUPIHAN-HERMOSA
Province of Bataan
ADELAIDA VILLANUEVA,
Plaintiff,
PRISCILLA G.
SARMIENTO,
Defendant.
X-----------------------------------------------------X
PRE-TRIAL BRIEF
FOR THE PLAINTIFF
Court, most respectfully submits this Pre-Trial Brief, and accordingly states as
follows:
G. Statement of willingness to enter into an amicable settlement indicating the

desired terms thereof or to submit the case to any of the alternative modes
of dispute resolution:

agreement with the defendant.
H. Summary of admitted fact and propose stipulation of facts:
Admitted facts:
a. the existence of the loan obtained by the defendant from the plaintiff;
b. the referral of the matter to the Barangay prior to the filing of the case
with the Honorable Court;
c. defendant is a barangay officer of San Ramon, Dinalupihan, Bataan;
the receipt of the demand letter sent by the plaintiff to the defendant.
b. Would the defendant admit that the original of Transfer Certificate of

Title No. CLOA-4092 mentioned in the complaint is in the custody of the
plaintiff having been received by the latter from the former by way of
collateral to the loan she obtained from the plaintiff?
c. On January 2008, defendant promised to pay her loan to the plaintiff;
d. To date defendant failed to pay her aforesaid loan to the plaintiff.
I. The issues to be tried or resolved:
a. Whether or not plaintiff has legal cause of action against the

defendant?
b. Whether or not defendant is liable to pay her loan to the
plaintiff?
c. Whether or not parties are entitled to damages.
J. The documents or exhibits to be presented, stating the purpose thereof:
Documents Purpose (s)
Loan Document
To prove that defendant obtained a loan
in the amount of P 50,000.00 from the
plaintiff on June 21, 2005 with 7%
monthly interest payable within six (6)
months or until December 21, 2005.
TCT CLOA No. 4092

To prove that the said title is in the
custody of the plaintiff and the same was
used as collateral to the loan obtained by
defendant from the plaintiff.
Promise to Pay Document

To prove that defendant signed another
loan document promising to pay
plaintiff the amount of P 100,000.0o0
which shall cover all her indebtedness to
the plaintiff to be paid on March 2008.
Demand Letter
To prove that plaintiff sent a demand
letter to the defendant for the payment
of the latter’s loan and that despite
receipt thereof, defendant failed to pay,
leading to the filing of the instant case.
Certification issued by the
Office of Brgy. San Ramon,
Dinalupihan, Bataan
To prove that the matter was referred to
the Office of Barangay San Ramon,
Dinalupihan, Bataan prior to its filing to
the Honorable Court. There was
mediation but the same failed.
Plaintiff reserves the right to present other documents as the need
arises and as trial progresses.
K. Manifestation of their having availed or their intention to avail themselves

of discovery procedure or referral to commissioners:
As of this writing, plaintiff has no intention to avail of the
discovery procedure or referral to commissioners.
L. The number and names of the witnesses, the substance of their testimonies,
and the approximate number of hours that will be required by the parties for
the presentation of their respective witnesses.
Names Address Substance
Adelaida Villanueva Tucop, Dinalupihan,

Bataan To prove allegations
contained in the
Complaint.
Plaintiff reserves the right to present other witnesses as the need arises
and as trial progresses.

Counsel for Defendant Paule
PTR No. 8750172, 01/03/2008
IBP No. 661896, 12/28/2007
Bataan
Copy furnished:
Mr. & Mrs. Roque/Priscilla Sarmiento

Defendants
San Ramon, Dinalupihan, Bataan
Supreme Court
OF DINALUPIHAN-HERMOSA
Province of Bataan
ADELAIDA VILLANUEVA,
Plaintiff,
PRISCILLA G.
SARMIENTO,
Defendant.
X-----------------------------------------------------X
MANIFESTATION
Court, most respectfully manifests that:
1. On May 15, 2008, the instant case was filed;
2. On June 18, 2008, plaintiff received a copy of defendant’s Answer

dated June 13, 2008;
3. On June 25, 2008, by virtue of defendant’s virtual admission of the

material allegations contained in the Complaint as found in her
Answer, plaintiff filed her “Motion to Direct Judgment on the
Pleadings” dated June 23,2008 on June 25, 2008;
4. On June 25, 2008, (perhaps in the afternoon after the Motion to

Direct Judgment on the Pleadings has been filed), plaintiff received a
copy of the Notice of Pre-Trial dated June 16, 2008;
5. On June 26, 2008, plaintiff was in receipt of a Motion to Admit
Amended Answer filed by defendant;
6. On June 30, 2008, plaintiff filed her Comment/Opposition to

Defendant’s Motion to Admit on several grounds stated therein;
7. Considering that there was already a Notice of Pre-Trial, plaintiff

opted to file her Pre-Trial Brief for her compliance but manifests her
desire to wait for the resolution of the two (2) motions pending before
the Honorable Court. First is the Motion to Direct Judgment on the
Pleadings filed by the Plaintiff and second is the Motion to Admit
Amended Answer filed by the defendant;
WHEREFORE, the above premises considered, plaintiff manifests her

willingness to submit the two pending incidents (motions stated in paragraph 7
above) for the resolution of the Honorable Court.
Respectfully manifested.

Counsel for Petitioner
PTR No. 8750172, 01/03/2008
IBP No. 661896, 12/28/2007
Bataan
Copy furnished:
Mr. & Mrs. Roque/Priscilla Sarmiento

Defendants
San Ramon, Dinalupihan, Bataan
Supreme Court
Branch V
Dinalupihan, Bataan
Jose S. Salazar,
Plaintiff,
Kyoryo, Inc., Et.Al.,

Defendants.
X-----------------------------------------------X
Pre-Trial Brief
For the Plaintiff

Honorable Court, most respectfully submits this Pre-Trial Brief, and
A. Brief statement of the parties’ claims and defenses:
This is a case filed by plaintiff against defendants on July 17,

2006 for collection of sum of money and damages. Plaintiff is the
owner of JS Salazar Trading, a single proprietorship with stores in
Sta. Isabel, Dinalupihan, Bataan, engaged in selling construction
materials. Defendants purchased on credit several construction
materials from plaintiff in the year 2005 in the amount of P
1,356,261.88. Defendants failed to pay the same despite repeated
demands, causing the filing of the instant case against them.
Defendants denied the claim of the plaintiff.
B. Respective proposals for amicable settlement or submission to

arbitration:
agreement.
C. Facts, documents, matters which may be admitted, agreed upon or

made the subject of stipulation:
The plaintiff would like to request for stipulation of the

following proposal for admission:
a. Plaintiff is the owner of JS Salazar Trading which is a

single proprietorship establishment dealing with the
sale of construction/building materials;
b. Defendant is a duly registered corporation operating
under the laws of the Republic of the Philippines. The
other three defendants are connected with the
defendant corporation;
c. Defendants purchased several construction materials
from plaintiff in the year 2005 amounting to P
1,356,261.88 and has not been paid yet to date;
d. Demand letter was sent by plaintiff to defendants prior
to the filing of this case;
D. Statement of the issues:
Whether or not there plaintiff is entitled to be paid with the

amount of P 1,356,261.88 representing cost of the materials
purchased on credit by defendants and whether or not he is entitled
to damages by reason of the malevolent acts of the defendants.
E. Applicable laws and jurisprudence:
Pertinent provisions in the Civil Code of the Philippines.
F. Number of witnesses to be presented with an abstract of the

testimonies and the approximate time required by them for the
presentation of their respective evidence:
Plaintiff will be presenting the following:
i. Jose Salazar, Jr.

ii. Others to be named during the pre-trial conference
G. Copies of all documents intended to be presented so that they may

be marked as exhibits:
Those mentioned in the complaint according to how they were

attached.
A Summary of Purchases from November 24-30, 2005
B Demand Letter
H. Proposed amendment of pleadings, if any:
None so far.
I. Available trial dates of counsel for complete evidence presentation,

which must be within three (3) months from the first day of trial:
So as to avoid conflict, scheduled dates will be given during

the pre-trial conference.
J. Such other matter as may be necessary for the early disposition of

the action.
None insofar as the plaintiff is concerned.

PTR No. 8750172, 01/03/2008
IBP No. 661896, 12/28/2007
Bataan
Copies furnished:
Kyoryo, Inc., Nonabelle and Ryochi Tomasada

Defendants
4566 A. Quintos St., Poblacion
Makati City
Ms. Rosita Oculam

Defendant
Portacio Apartment Meralco Road, Zone 2
Signal Village, Taguig City
July 3, 2008
Office of the Ombudsman

Field Investigation Office
General Investigation Bureau-C
5th Floor Ombudsman Bldg., Agham Road
Diliman, Quezon City
In Re: CPL-C-06-1566
Certification
In compliance with your subpoena dated May 23, 2008, the

following are hereby certified to be correct as per available records in our
office (particularly their respective birth certificates), to wit:
Names Date of Birth Address of Parents
The above documents however may not be accurate considering that

the details given by your good office are incomplete. The address as stated
in the above could not be the address at present.
This certification is being issued for legal purposes only.
Subscribed and sworn to before me this 3rd day of July, 2008.

Affiant exhibiting to me her Community Tax Certificate No. Cc12006-
16008986 issued on January 15, 2008 at Dinalupihan, Bataan.
Doc. No.
Page No.
Book No.
Series of 2008.
July 3, 2008
Office of the Ombudsman

Field Investigation Office
General Investigation Bureau-C
5th Floor Ombudsman Bldg., Agham Road
Diliman, Quezon City
In Re: CPL-C-06-1566
Dear Sir/Madam:
Attached hereto is the Certification requested as per Subpoena

issued by your good office dated may 23, 2008.
Please be informed that this office could not as yet submit a

certification as to the dates of birth and the addresses of the other persons
named in the attached document in your aforesaid subpoena, for the
following reasons:
a) the details are not complete;

b) their names do not match with our records;
c) or simply they have no records with our office;
We will be glad to entertain query from your end. Should you have
further request, please do not hesitate to let us know.
Thank you.
Very truly yours,
Subscribed and sworn to before me this 3rd day of July, 2008.

Affiant exhibiting to me her Community Tax Certificate No. Cc12006-
16008986 issued on January 15, 2008 at Dinalupihan, Bataan.
Doc. No.
Page No.
Book No.
Series of 2008.

5 891776824311283718

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Republic of the Philippines

Third Judicial Region

Spouses Carlito V. Sapno and Rosario

- versus - Case No. 1584

Rowena P. Ganaden and Jerry R.

Pre-Trial Conference Brief

A. A statement of their willingness to enter into amicable settlement or

Plaintiffs are willing to enter into reasonable amicable

B. Summary of admitted facts and proposed stipulations of facts:

 Plaintiffs entered into a contract to sell with the

B. The issues to be resolved:

 Who has better right of possession on the subject property;

C. Documents to be presented by the plaintiffs:

Plaintiff reserves the right to mark other documents during trial.

D. The number and names of the witnesses, the substance of their

The names and address of the witnesses as well as the

Dinalupihan, Bataan, August 04, 2016.

Public Attorney’s Office

Spouses Fermin Langit and

- versus - Civil Case No. DH-1416-15

Pre-Trial Conference Brief

A. A statement of their willingness to enter into amicable settlement or

Plaintiffs are willing to enter into reasonable amicable

B. Summary of admitted facts and proposed stipulations of facts:

 Plaintiffs are the owners of a parcel of rice land,

C. The issues to be resolved:

 Whether the Plaintiffs are entitled to the relief sought in their

N. Transfer Certificate of Title No. 038-2014008051

E. The number and names of the witnesses, the substance of their

The names and address of the witnesses as well as the

Dinalupihan, Bataan, August 03, 2016.

Counsels for the Plaintiffs

Juvy Mell B. Sanchez-Malit

Legal Services Department

The above pleading will be served to the opposing counsels by

Republic of the Philippines

Gregorio I. Cudia, represented by

- versus - Case No. 1579

Juliet Cahilig, Et. Al.,

Pre-Trial Conference Brief

E. A statement of their willingness to enter into amicable settlement or

Plaintiff is willing to enter into reasonable amicable

F. Summary of admitted facts and proposed stipulations of facts:

 Plaintiff is represented herein by his attorney-in-fact,

G. The issues to be resolved:

 Whether or not the Plaintiff is entitled to the possession of the

H. Documents to be presented by the plaintiff:

X. Special Power of Attorney executed on March 02, 2015

Plaintiff reserves the right to mark other documents during trial.

I. The number and names of the witnesses, the substance of their

The names and address of the witnesses as well as the

Dinalupihan, Bataan, August 01, 2016.

Atty. Juliano P. Nacino

- versus – Civil Case No. DH-1365-14

J. A statement of their willingness to enter into amicable settlement or

Not allowed in annulment of marriage cases.

K. Summary of admitted facts and proposed stipulations of facts:

Proposed Stipulation of facts:

 Fact of marriage: Parties got married on December 23, 1992 in

L. The issue to be resolved:

 Whether or not there is legal ground or there are legal grounds

M. Documents to be presented by the plaintiff:

A Marriage Contract of the parties