Republic of the Philippines

MUNICIPAL TRIAL COURT

Bayombong, Nueva Vizcaya
RIZALINO R. VILLANUEVA,
ROSALINDA V. REGUYAL,
HEIRS OF RONALD R. VILLANUEVA, namely: MADELYN C.
VILLANUEVA, and EMMA C.
VILLANUEVA, and HEIRS OF
ROSENDO R. VILLANUEVA,
namely: RAYMOND Q. VILLANUEVA, and RICHIE V. GAVINA,
Plaintiffs,
-versus-

CIVIL CASE NO.4006

For : Unlawful Detainer With
Prayer for Issuance of Temporary Restraining Order and/or
Writ of Preliminary Injunction
and Damages

ESTEBAN BAUTISTA, SR., SPOUSES

ESTEBAN
BAUTISTA,
JR., AND
JULIANA BAUTISTA, SPOUSES MARIO
BAUTISTA AND
ERFEL BAUTISTA,
SPOUSES
ROMEO RIVERA
alyas
IBONG and FE RIVERA, NORA GACO
RIVERA,
ESTRELLA
BALANZA,
BRANDO BALANZA, ALLAN BALANZA,
SPOUSES
PEDRO BALANZA AND
OLIVIA BALANZA, SPOUSES JUANITO
BALANZA LILIA BALANZA, SPOUSES
MARCELINO CAALING AND
NIDA
CAALING, LOLITA LAURETA, JORDAN
LAURETA, ADONG LAURETA, LILIA
MARBIBI, ALONG MARBIBI SPOUSES
FRED FRAGATA AND EDITHA MARBIBI
FRAGATA,
Defendants.
x------------------------------------------------------------x

PRE-TRIAL BRIEF
COME NOW the plaintiffs, through counsel, respectfully submits
to this Honorable Court their Pre-Trial Brief as follows:

I.

AMICABLE SETTLEMENT
The plaintiffs are willing to settle with the defendants
provided they vacate the subject lot and remove their
improvements at their own expense and without any
precondition.

II.

PROPOSED STIPULATION OF FACTS

Facts admitted:
1. Legal capacities of the parties to sue and to be sued;
Facts proposed for admission:
1. The disputed lot is covered by TCT No. T-97976 registered
in the name of Rolando, Rizalino, Rosalinda, Remedios,
Rosel, Ronald, all surnamed Villanueva, some of whom are
the plaintiffs in this case;
2. The defendants are presently occupying the parcel of land
covered by TCT No. T-97976;
3. The plaintiffs, through counsel, demanded the defendants to
vacate the lot covered by TCT No. T-97976 but they
refused to leave.

III.

DOCUMENTARY EVIDENCE
The documentary exhibits for the plaintiffs consist of all the
documents which they identified and attached in their
Complaint with reservation to present more during the trial;

IV.

WITNESSES
1.
2.
3.
4.
5.
6.

Dominga Dela Cruz-Villanueva;

All the plaintiffs;
The Register of Deeds of Nueva Vizcaya;
The Municipal Assessor of Bayombong, Nueva Vizcaya;
The Municipal Treasurer of Bayombong, Nueva Vizcaya;
The Municipal Agrarian Reform Officer of Bayombong,
Nueva Vizcaya

V.

ISSUES
1. Who between the parties has the better right of possession
over the property in question;
2. Who is entitled of damages and how much?
RESPECTFULLY submitted. Bayombong, Vizcaya.

FIDEL G. SANTOS
Counsel for the Accused
156 Bonfal West, Bayombong, N. Vizcaya
PTR No. 1914695; dated Dec. 1, 2016 for 2017
IBP Fees paid OR No. 1028768; Dec. 1, 2016 for 2017
MCLE Compliance No. V-0010617 Sept. 17, 2015
Roll No. 48362
Tel. No. 805-35-85/CP No. 09085021774

Copy furnished:
Atty. John Severino G. Bagasao
Counsel for Defendants
Bayombong, Nueva Vizcaya