REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

FIRST JUDICIAL REGION
BAGUIO CITY, BRANCH NO. ____

HEIRS OF DOMINGO SALAZAR

(REPRESENTED BY CELIA SALAZAR),
Plaintiff,
CIVIL CASE NO. 143
-Versus - FOR DAMAGES

AARON JAMES E. CO,

Defendant,
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PRE-TRIAL BRIEF
(For the Plaintiff)

Plaintiff, by counsel, unto the Honorable Court, submit pre-trial brief

as follows:

I. POSSIBILITY OF STATEMENT

Without waiving the Plaintiffs right or defenses, they are

open for any reasonable proposal of an amicable settlement of
the plaintiff but only as to the civil aspect of the case

II. BRIEF STATEMENT OF CLAIMS

a. Plaintiff claims that the Defendant, by reason of his negligence

and lack of foresight in driving his car, has resulted to the
confinement by reason of the injuries of Domingo Salazar and
later on his death which caused not only Financial Loss to the
victim but also emotional and mental suffering as a result of the
death of their Relative.

b. Plaintiff now claims P 198,000.00 for hospital expenses, P

50,000.00 for Moral damages, P 20,000.00 for Attorneys fees
and P 30,000.00 for exemplary damages in the total amount of
P 298,000.00.
.
II. STIPULATION OF FACTS

The Plaintiff admits only those facts stated in the

complaint and specifically denies all allegation presented by the
 Plaintiff in his answer except for those of their personal
circumstances.

III. DOCUMENTARY EVIDENCES

ANNEX A - Certificate of Registration of the Toyota Fortuner with Plate

No. FUB 036
ANNEX B -Statement of Grace U. Rabanal
ANNEX C -Copy of the Police Blotter in connection with the incident
ANNEXD - Medical Certificate of Domingo Salazar
ANNEX E - Death Certificate of Domingo Salazar
ANNEX F - Summary of Statement of Account issued by the Baguio
General Hospital
ANNEX G - Photographs of place where incident took place
IV. WITNESS
1. Grace U. Rabanal

Plaintiff reserves the right to present other additional documentary

exhibits and witnesses during the trial of the case if need be.

V. ISSUES

1. Whether or not the Defendants negligence and lack of foresight

resulted to the death of Domingo Salazar

2. Whether or not the Defendant is civilly liable for the damages

suffered by the Plaintiffs.

VI. AVAILABLE TRIAL DATES

April 2, 2016, April 9, 2016 and April 16, 2016

RESPECTFULLY SUBMITTED
2 April 2016, Baguio City.

ATTY. MAE ANN Y. BADUA

Notary Public
Notarial Commission No.331-2018
Roll No. 071015
PTR No.7313108, 1/3/18
IBP No. 785625, 1/2/18
BADUA-AGUILAR & Associates
Alviar Tower Building
Baguio City, Philippines