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Pre Trial Brief

The document is a pre-trial brief for the plaintiff, Racheal B. Santos, in a civil case against Jocelyn Uy for the collection of a loan amounting to Php 600,000. The plaintiff is open to amicable settlement and outlines the facts for stipulation, issues regarding breach of contract, and documents to be presented during the trial. The brief also mentions the intention to utilize discovery procedures and lists potential witnesses.

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Racheal Santos
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21 views2 pages

Pre Trial Brief

The document is a pre-trial brief for the plaintiff, Racheal B. Santos, in a civil case against Jocelyn Uy for the collection of a loan amounting to Php 600,000. The plaintiff is open to amicable settlement and outlines the facts for stipulation, issues regarding breach of contract, and documents to be presented during the trial. The brief also mentions the intention to utilize discovery procedures and lists potential witnesses.

Uploaded by

Racheal Santos
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES


Legazpi City
Branch 10

RACHEAL B. SANTOS Civil Case No. 2025-0001


Plaintiff, For: Collection of Sum of
Money,
-
versus
-
JOCELYN UY
Defendant.
x----------------------------------x

PRE-TRIAL BRIEF FOR THE PLAINTIFF

COMES NOW, PLAINTIFF by and through the undersigned counsel,


unto this Honorable Court, most respectfully manifests and avers, that:

I. POSSIBILITY OF AMICABLE SETTLEMENT:

Plaintiff is open to accept proposals to settle the instant case amicably


on terms that are just and equitable to all concerned. Herein Plaintiff is
likewise submitting herself, to the mediation and dispute resolution provided
for by laws.

II. FACTS FOR STIPULATION AND ADMISSION:

A. On Stipulation of Facts:

The Plaintiff stipulates or proposes the following for admission by


Defendant:

1. Plaintiff loaned the defendant with the total amount of SIX


HUNDRED THOUSAND PESOS (Php 600,000.00) on September 5,
2019.

2. That Plaintiff after several demands of payment against the


defendant, and sent a final demand but the latter failed to
comply with said obligations.

B. On the Admission of Facts:

Plaintiff denies the allegations stated in the Answer of the defendant.

ISSUES:

1. Whether or not the defendant is guilty of breach of contract for failure


to settle her unpaid loan to the plaintiff; and

2. Whether or not the defendant is liable for damages.

Page 1 of 2
DOCUMENTS TO BE PRESENTED:

1. Annex “A” - Contract of Loan dated 17 November 2019;


2. Annex “B” - Screenshots of her Facebook posts;
3. Annex “C” - Conversations in SMS and FB messenger, call
records;

4. Annex “D” - Barangay Blotter signed by the Punong Barangay;

5. Annex “E” - Certificate to File Action;

Plaintiff further prays for the reservation to mark other exhibits and
documents during the course of the Pre-Trial and Trial.

INTENTION TO AVAIL OF DISCOVERY PROCEDURES:

Plaintiff intends to avail of the modes of discovery under the 1997


Rules of Civil Procedure.

NUMBER OF WITNESSES:

1. Punong Barangay- Brgy. San Roque, Tabaco City, Albay.


2. Jean Vargas- Plaintiff’s Secretary

TRIAL DATES:

As may be agreed upon between the parties subject to the Honorable


Court’s Calendar.

APPLICABLE LAWS and JURISPRUDENCE:

1. The Rules of Court;


2. The New Civil Code of the Philippines; and
3. Other Related Laws Supreme Court rulings.

RESPECTFULLY SUBMITTED.

October 15, 2024.

ATTY. HUWAN D MACULANGAN


Counsel for the Plaintiff
Attorney’s Roll No. 12345
IBP No. 6789/10-18-2026 / Albay
PTR No. 5681790 / 02-12-11
MCLE No. 54321 / 10-18-2026

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