Republic of the Philippines

Metropolitan Trial Court

National Capital Judicial Region

Quezon City

AAA,

Plaintiff, Civil Case no._____________

Vs.

BBB, for Forcible Entry

Defendant.

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PRE-TRIAL BRIEF

Plaintiff, by counsel, respectfully submit this pre-trial brief containing:

I. AMICABLE SETTLEMENT

Plaintiff is willing to amicably settle the case upon such terms which are beneficial to both
parties.

II. SUMMARY OF SUBMITTED FACTS

1. Plaintiff is the registered owner of a 400 square meter lot along Pangilinan Street San
Antonio, Quezon City covered by Transfer Certficate of Title No. 20020202 issued by the Registry of
Deeds Quezon City;

2. That through stealth, strategy and machination, Defendant was able to construct a house on
a lot adjacent to the Plaintiff’s aforementioned lot with the portion thereof encroaching upon such
property;

3. That the encroachment was discovered by the Plaintiff only when the said lot was surveyed
on November 2016 for the purpose of enclosing Plaintiff’s lot;

4. That Plaintiff sent Defendant a Letter to Vacate dated January 5, 2017;

5. That Defendant refused to remove the materials on Plaintiff’s property.

III. ISSUES TO BE RESOLVED

1. Whether or not Defendant encroached upon Plaintiff’s property.

 IV. WITNESSES

Name Purpose

1. AAA

2. Register of Deeds Quezon City

3. Land Surveyor

4.

Plaintiff reserves his right to present additional testimonial evidence as the exigencies of the trial may
require.

V. DOCUMENTARY EXHIBITS

Name Purpose

1. Transfer Certficate of Title No. 20020202

2. Letter to Vacate

3. Geodetic Map

4.

Plaintiff reserves his right to present additional documentary exhibits as the exigencies of the trial
may require.

VI. MODES OF DISCOVERY

Plaintiff intends to use the modes of discovery available under the Rules but not limited to
deposition.

VII. APPLICABLE LAWS AND JURISPRUDENCE

PRAYER

Wherefore, premises considered, Plaintiff respectfully prays that the pre-trial brief be noted.

Such other reliefs just and equitable as the court may grant.

Respectfully submitted

Date, Quezon City Signed by Counsel

Address

Email address

IBP
 Roll No.

PTR No.

MCLE Compliance No.

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