REPUBLIC OF THE PHILIPPINES

Municipal Trial Court in Cities

Branch 1, Cebu City

JUAN ILOK,
Plaintiff,

-versus- CIVIL CASE NO. CEB-12345

BRAD ARMPIT,
Defendant. FOR: SUM OF MONEY
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PRE-TRIAL BRIEF

COMES NOW, plaintiff through the undersigned counsel and unto this Honorable Court most
respectfully submit this pre-trial brief to, wit:

I.

BRIEF STATEMENT OF FACTS

1.On March 1, 2007, Defendant is indebted to the plaintiff in the amount of ONE HUNDRED FIFTY
THOUSAND PESOS (P 150,000.00) without any written contract and was witnessed by Pedro Siponon
and Jose Kogmohon;

2. Subsequently, On July 20, 2007, defendant went to the house of the plaintiff to cause partial payment
in the amount of FIFTY THOUSAND PESOS (Php 50,000.00);

3. Consequently, the aforesaid payment was received by the plaintiffs minor son aged 17 years old;

4. On July 31, 2007, defendant made its final payment in the amount of ONE HUNDRED THOUSAND
PESOS (P100,000.00) but the previous payment was not received by the plaintiff in lieu that his son was
not turn over the said money;

5. However, the plaintiff told the defendant that it was not his responsibility to rectify the payment by
mistake made by the defendant since the latter is still liable;

II.

NUMBER OF WITNESS TO BE PRESENTED

 Plaintiff will present three (3) witnesses and barring long cross-examination, in their testimonies
could each be terminated in thirty (30) minutes.

III.

Abstract Testimonies of Witnesses for the Plaintiff

1. To substantiate plaintiffs claim as alleged in the complaint

2. To identify relevant documents to support Plaintiffs claim

IV.

Documents intended to be presented

Plaintiff reserves his right to present and mark his documentary exhibits in the course of the
proceedings of this case.

V.

Admissions

Plaintiff limits his admission to those alleged in the Complaint

VI.

Applicable Laws and Jurisprudence

Plaintiff reserves his right to submit the appropriate memorandum or position paper citing the
laws and jurisprudence applicable to this case.

VII.

Availment of Alternative Modes of Dispute Resolution

Plantiff is hereby willing to avail the possibility of settlement of claims by any methods of
Alternative Modes of Dispute Resolution.

VIII.

Issue
1. Whether or not Plaintiff have causes of action against the defendant;
2. Whether or not Plaintiff is entitled to any and all damages contemplated in his Complaint.

RESPECTFULLY SUBMITTED UPON RECEIPT

October 3, 2016 Cebu City, Philippines

ATTY. PARK K. TILAOPAO

Counsel for the Plaintiff
Unit 1234 Apple One Building
Cebu City, Philippines
Roll No. 123453, IBP Member Lifetime 3/12/12
PTR No. 23124, Cebu City 12/31/15
MCLE Compliance No. VI-23455, Series of 2015

Copy Furnished:

Atty. DESIREE E. KURIMAO

Counsel for the Defendant
KURIMAO, KURIMAO and ABLAO LAW OFFICE
Suite 235 The Tower
Malate, Manila