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Republic of the Philippines

National Capital Judicial Region


Municipal Trial Court
Angono, Rizal

RIZAL PROVINCIAL GOVERNMENT,


Plaintiff,
-versus-

SCA Case No. _______


For: Unlawful Detainer

Fortunato Andaya, Noel Valeriano,


Brando Abocatal, Tomas Abocatal,
Roque Estornino, Michelle Galising,
Evelyn Oot, Virgilio Pascua,
Norma Pensocas, Corazon San Antonio,
Jose Rivera, Jojo Rivera,
Manuel Rivera,
Defendants.

PRE-TRIAL BRIEF

Plaintiff, Rizal Provincial Government (hereinafter


referred to as RPG for brevity), through the undersigned
counsel and unto this Honorable Court most respectfully
submits this Pre-Trial Brief, to wit:

AMICABLE SETTLEMENT

Plaintiff is willing to settle the case amicably as long


as the terms thereof are reasonable.

FACTS FOR STIPULATION

Plaintiff, in order to expedite the proceedings of this


case, proposes the following facts for stipulation and/or
submission:

1. Plaintiff is the registered owner of the lot subject matter of


this case;
2. Defendants are presently occupying the lot subject matter
of this case;
3. Defendants, without justifiable reason, continuously failed
and refused to vacate said premises despite notice to
vacate sent to them;

ISSUES

1. Whether or not defendants occupancy on the lot subject


matter of this case becomes illegal after their failure to
vacate the same without justifiable reason and despite
notice to vacate?
2. Whether or not defendants are liable for the costs of
litigation.

DOCUMENTS FOR MARKING

Plaintiff would like to propose the markings of the


following documents, to wit:

Exhibit A- Resolution No. 083, s. 3012


Exhibit B- Tax Declaration No. 01-0005-09999
Exhibit

C-

Transfer

Certificate

of

Title

No.

068-

2011007648
Exhibit D- SP Resolution No. 142, s. 2012
Exhibit E- Demand Letter dated June 28, 2012 for
Tomas Abocatal
Exhibit E-1- Signature appearing at the bottom of the
demand letter for Tomas Abocatal
Exhibit F- Demand Letter dated June 28, 2012 for
Evelyn Onot
Exhibit F-1- Signature and date appearing at the bottom
of the demand letter for Evelyn Onot
Exhibit G- Demand Letter dated June 28, 2012 for
Michelle Galising
Exhibit G-1- Signature and date appearing at the bottom
of the demand letter for Michelle Galising
Exhibit H- Demand Letter dated June 28, 2012 for
Jojo Rivera
Exhibit H-1- Signature appearing at the bottom of the
demand letter for Jojo Rivera
Exhibit I- Demand Letter dated June 28, 2012 for
Virgilio Pascua
Exhibit I-1- Signature and date appearing at the bottom
of the demand letter for Virgilio Pascua
Exhibit J- Demand Letter dated June 28, 2012 for
Brando Abocatal

Exhibit J-1- Signature appearing at the bottom of the


demand letter for Brando Abocatal
Exhibit K- Demand Letter dated June 28, 2012 for
Corazon San Antonio
Exhibit K-1- Signature appearing at the bottom of the
demand letter for Corazon San Antonio
Exhibit L- Demand Letter dated June 28, 2012 for
Roque Estornino
Exhibit L-1- Signature appearing at the bottom of the
demand letter for Roque Estornino
Exhibit M- Demand Letter dated June 28, 2012 for
Jose Rivera
Exhibit M-1- Signature and date appearing at the bottom
of the demand letter for Jose Rivera
Exhibit N- Demand Letter dated June 28, 2012 for
Manuel Rivera
Exhibit N-1- Signature appearing at the bottom of the
demand letter for Manuel Rivera
Exhibit O- Demand Letter dated June 28, 2012 for
Noel Valeriano
Exhibit O-1- Notation Refuse to Sign appearing at the
bottom of the demand letter for Noel Valeriano
Exhibit P- Demand Letter dated June 28, 2012 for
Fortunato Andaya
Exhibit P-1- Notations appearing at the left portion of
the
demand letter for Fortunato Andaya

Exhibit E-1-

Plaintiff reserved the right to mark other documents


during the course of trial, if necessitated.

WITNESSES/ AFFIDAVITS

Plaintiff will present/submit the affidavits of the


following:
1. Affidavit of Santiago M. Abrera, President Kapisanan ng
Maybahayan sa Purok 6 & 7 Inc.
2. Affidavit of _______________________ of Rizal Provincial
Government, Server of Demand Letters

Plaintiff reserved the right to present/submit other


witnesses/affidavits during the course of the trial/position
paper, if necessitated.

RESPECTFULLY SUBMITTED.

Antipolo City for Angono Rizal, June 10, 2013

OFFICE OF THE PROVINCIAL LEGAL OFFICER


Counsel for the Plaintif
Rizal Provincial Capitol Bldg.,
Circumferential Road Corner P. Oliveros St.,
Brgy. San Roque, Antipolo City 1870
By:
ATTY. ROSELLE ANDALLO RAMILO
OIC- Provincial Legal Officer
PTR No. 9611411/ 01-01-13/ Rizal
IBP No. 882447/ 01-04-13/ Rizal
Roll No. 43742
MCLE Compliance No. 111-0020170
By:
ATTY. MARIVIC MORGIA FERUELO
Roll of Attorney No. 61649
IBP No. 907512/ 01-16-13/ Rizal
PTR No. 9739131/ 01-30-13/ Rizal
MCLE Compliance: IV-0013224

Copy Furnished:
Atty. Franco Fernandez de Guzman
Cerezo and De Guzman Law Office
Counsel for Jose Rivera, Jojo Rivera and Manuel Rivera
No. 4-C K-9th Street corner Col. Salgado Street
West Kamias, Quezon City

Fortunato Andaya
Noel Valeriano
Brando Abocatal
Tomas Abocatal
Roque Estornino
Michelle Galising
Evelyn Oot
Virgilio Pascua
Norma Pensocas
Corazon San Antonio,
Brgy. Mahabang Parang,
Angono Rizal

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