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
x--------------------------------------------x

PRE-TRIAL BRIEF

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

I. WILLINGNESS TO ENTER INTO AN AMICABLE SETTLEMENT AND POSSIBLE TERMS OF ANY SUCH
SETTLEMENT

1.1. Plaintiff is open to settling this dispute amicably, subject to a concrete proposal that is fair
and reasonable and a reciprocal manifestation of openness from defendant,

1.2. Pursuant to Rule 18 of the 1997 Rules of Civil Procedure, plaintiff respectfully submits that
the desired terms of any amicable settlement would involve, first, an admission of amount due and
owing to plaintiff and, second, a schedule of payments.

II. BRIEF STATEMENT OF CLAIMS AND DEFENSES

2.1 Plaintiff claims that defendant failed to pay unpaid balance of FIFTY THOUSAND PESOS (Php
50,000.00) for the Rolex watch delivered to the defendant.

2.2 Defendant raise as defenses that the said unpaid balance was already paid and there is no
obligation on the part of the defendant to repay the plaintiff despite the averments of the plaintiff that
the said payment was mistakenly paid by the latters son.

III. FACTS AND OTHER MATTERS ADMITTED BY THE PARTIES

3.1. Defendant admits only those facts stated in their Answer, i.e., their personal circumstances
and the existence of debt.

IV.
NUMBER OF WITNESS TO BE PRESENTED

Defendant 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 Defendant

1. To disprove plaintiffs claim as alleged in the complaint

2. To identify relevant documents to support Defendants defense

IV.

Documents intended to be presented

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

V.

Applicable Laws and Jurisprudence

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

VII.

Issue

1. Whether or not Plaintiff have causes of action against the defendant are not tenable;

RESPECTFULLY SUBMITTED UPON RECEIPT

October 3, 2016 Manila for Cebu City, Philippines

KURIMAO, KURIMAO and ABLAO LAW OFFICE

Counsel for the Defendant
Suite 235 The Tower
Malate, Manila
 By:

Atty. DESIREE E. KURIMAO

Roll No. 98765
IBP No, 12345/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila

Copy Furnished:

ATTY. PARK K. TILAOPAO

Counsel for the Plaintiff
Unit 1234 Apple One Building
Cebu City, Philippines