REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Pasay City, Branch ___

GAIL MONTERO,
Plaintiff,

-versus- CIVIL CASE NO.____________

For: Declaration of Nullity of
Marriage under Article 41 of the
Family Code of the Philippines

CALIXTO MONTERO,
Defendant.
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PRE-TRIAL BRIEF

PETITIONER, through Counsel, and unto this Honorable Court, respectfully

submits this Pre-Trial Brief, as follows:

I. STATEMENT OF FACTS AND CASE

1. That this is a case for nullity of marriage;

2. That the petitioner and the respondent met and entered into a
relationship in 2011;
3. That the petitioner and the respondent was married on June 20, 2014;
4. That sometime in 2016, the petitioner discovered that the respondent
was previously married to Sunshine Dela Cruz in 2009.
5. That the petitioner confirmed the information from the Philippine
Statistics Authority/National Statistics Office on August 23, 2016;
II. WILLINGNESS TO ENTER INTO AMICABLE SETTLEMENT

1. The petitioner is NOT open to settling this dispute amicably;

2. The petitioner is NOT willing to submit herself to mediation and other
alternative modes of dispute resolution.

III. ISSUES TO BE TRIED

Plaintiff submits that the following issues are subject to proof:

1. The marriage between the plaintiff and defendant on June 20, 2014 is
void;
2. The respondent has committed a bigamous marriage

IV. TESTIMONIAL EVIDENCE

The PETITIONER intends to present one (1) or two (2) witnesses to

prove her allegations and claims

V. EVIDENCE FOR MARKINGS

The PETITIONER requests the markings as exhibits of the following
documents:

1. Marriage Contract between Calixto Montero and Sunshine Dela Cruz;

2. PSA/NSO Certification that the respondent contracted two (2)
marriages

VI. SPECIFIC TRIAL DATES

It is respectfully requested that the trial dates be set during the pre-trial
conference to dates most convenient to this HONORABLE COURT and
to all the parties.

Respectfully submitted.

October 17, 2018, Pasay City.

ATTY._______
Counsel for the Petitioner