REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
PASIG CITY, BRANCH 161

FRA ALEJANDRO,
Plaintiff
CIVIL CASE NO. 042218
-versus-

FOR: COLLECTION OF SUM

OF MONEY

JASMIN MICAH JABAL,

Defendant
x--------------------------------------x

PRE TRIAL BRIEF OF THE PLAINTIFF

PLAINTIFF, through the undersigned counsel, respectfully submits
before the Honorable Court this Pre-Trial Brief:

I
Willingness to Enter into an Amicable Settlement
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,
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
Statement of Admitted Facts
1. That on October 12, 2015, Defendant Jasmin Micah
Jabal, executed a Promissory Note in favor of the
herein Plaintiff, in the amount of FIVE HUNDRED
THOUSAND

PESOS

(P500,

000.00),

which

indebtedness was to be paid on October 12, 2016,

with a monthly interest of one percent (1%) per month
starting from the month of November 2015 until the
note is fully paid;
2. That after the maturity of the Promissory Note, on
October 12, 2016, Defendant failed to make any payment;
3. That Plaintiff, on October 22, 2016 and November
7, 2016, demanded for the payment of Defendants account;
4. That Plaintiff did not receive any response from the
Defendant, and worse still, Defendant miserably failed to
comply with their obligation to the Plaintiff;
5. That the outstanding account of Defendant with
Plaintiff as of the filing of this complaint is P560, 000.00;
6. That in order to protect his right in filing this case,
Plaintiff was constrained to engage the services of counsel for
an agreed fee of P40, 000.00;
7. That in protecting his interest, Plaintiff had incurred
litigation expenses in the amount of P20, 000.00 for the present.
II
Number of Witness to be Presented

Plaintiff, Fra Alejandro will present herself as witness on

matters regarding the circumstances surrounding the case.
Barring long cross-examination, her testimony could be
terminated in thirty (30) minutes.
III
Abstract of the Testimonies of Witnesses for the Plaintiffs
1. To substantiate Plaintiffs claims as alleged in his
Complaint;
2. To identify relevant documents to support Plaintiffs
claims.
IV
Documents intended to be Presented
1. Annex A Promissory Note executed by Defendant
Purpose: To prove that the debt exists
2. Annex B Demand Letter dated October 22, 2016
3. Annex C Demand Letter dated November 7, 2016
Purpose: To prove that demands were made after the
date of maturity of the promissory note
V
Admissions
Plaintiff limits her admissions to those alleged in her
Complaint.
VI
Applicable Laws and Jurisprudence

Plaintiff reserves her right to submit the appropriate

memorandum citing the laws and jurisprudence applicable to
this case.
VII
Issues
1.

Whether or not Plaintiff have causes of action

against the Defendant;

2. Whether or not the alleged oral agreement validly
modifies the obligation to pay the sum under the
promissory note
VIII
Trial Dates
Subject to agreement on order to conform to the calendar
of this Honorable Court and counsels.
RESPECTFULLY SUBMITTED UPON RECEIPT.
Manila City, November 14, 2016.
RALPH AROMIN
Counsel for the Plaintiff
Unit 925, ITower Building, 939 P.Noval
St. Sampaloc, Manila
IBP NO. 887845
PTR NO. 1212345
MCLE Compliance No. 545313-8/26/215

Roll No. 85345

Copy furnished:
JASMIN MICAH JABAL
No.66 Morga St. Tondo, Manila 1013