STATEMENT OF THE FACT

NARRATES THE TRANSACTION OR

EVENT THAT CREATED THE LEGAL
DISPUTE AND LED TO THE FILLING
OF THE SUIT.
FUNCTION OF THE STATEMENT OF
THE FACT
INTRODUCE THE ISSUE OR ISSUES THAT
THE CASE PRESENTS
Details of the Statement of Facts

The test of sufficiency of the statement of

facts of the pleading is its ability to enable
the judge or the reader to understand, with
minimum words, the issue/s that must be
resolve and the arguments adduced on the
issue/s.
Plaintiff's Statement of Facts

A clear and concise statement in a

narrative form of the facts admitted by both
parties and of those in controversy.
Defendant's Statement of the Facts

Merely to state whether he accepts the

statement of facts in the petitioner's brief,
which includes the conflicting versions.
 STATEMENT OF THE CASE

STATEMENT OF FACTS
PLAINTIFF'S VERSION OF DEFENDANT'S VERSION
THE FACTS OF THE FACTS
THE ISSUES OR ISSUES

BODY OF THE ARGUMENTS

RELIEF
 Statement of Facts

Plaintiff De Leon testified that at 4:30 p.m. on March

10 she dropped in, as wedding coordinator, at a room at the
Hotel Intercontinental in Makati to see the bride who was
then preparing for her wedding at the nearby church. De
Leon left after a few minutes to attend to the venue of the
reception. At about 5 p.m., she returned to the bride's room
where defendant Casal, the bride's cousin, confronted her,
claiming that she must have taken her jewelry because she
alone came in and out of the room. Casal's jewelry was
missing. The hotel called the police to investigate the
matter.
They searched De Leon and took her fingerprints.

Casal testified, on the other hand, that she brought

with her to the bride's room a paper bag containing the
things that she would wear and a set of jewelry valued at
about Php 1M. She waited for her turn to be made-up and,
meantime, placed her paper bag on the table. The others in
the room were the bride's parents, other relatives, the
couturier, and the make-up artists. De Leon came in and left
after some minutes.
 After she had been made-up, Casal went to the
bathroom to put on her gown. When she later searched the
paper bag for her jewelry, it was gone. The police searched
the room and did not find it. They investigated those who
had access to the room, including De Leon. Casal denied
confronting the latter and implying that she took the jewelry.
Later after the wedding, the police came and took the
fingerprints of all the people who had access to the bride's
room at the time of the loss.
Source of Facts

Where the parties have conflicting versions, it would seem

best when you prepare the background or introductory facts
to extract your facts solely from the direct testimonies of the
witnesses from either side. The direct testimonies of
witnesses, as a rule, embody the versions that the parties
espouse.
 When the cross-examination have done some damage to
the testimony of your opponent's witnesses, use these in
the argument portion where they would have greater impact
and telling effect.