REPUBLIC OF THE PHILIPPINES

SIXTH JUDICIAL REGION

REGIONAL TRIAL COURT
ILOILO CITY
BRANCH 1
JUAN DE LA CRUZ,
04-235
Plaintiff,
Money with

Civil Case No.

For:

Sum

Prayer
Preliminary
-versus-

of
for

Attachment

JOSE DE LA CRUZ,
Defendant.
x----------------------------------x
DEFENDANTS PRE-TRIAL BRIEF
DEFENDANT, by counsel and to this Honorable Court,
respectfully submits this Pre-Trial Brief compliance with the
trial courts order dated, August 6, 2015.
I
Defendant is willing to enter into an amicable settlement of
the case, under terms and conditions agreeable to both
parties and submit to alternative modes of dispute
resolution;
II
Defendant admits only admits paragraphs 1, 2, and 8 of the
complaint
III
Issues to be resolved are the following:
A. Whether or not the plaintiff has cause of action.
B. Whether or not the demand to pay was made the plaintiff
upon the
defendant.
C. Whether or not defendant left the Philippines with the
intent to
defraud the plaintiff.
D. Whether or not defendant has sufficient property to cover
his
obligation to the plaintiff.
IV.
The Defendant intends to present the following Documentary
evidence:

A. Judicial Affidavit of Witness A.

Purpose: To prove that no demand was made by the
plaintiff:
B. Judicial Affidavit of Witness B.
Purpose: To prove that defendant is to leave
Philippines for
official business.
C. Statement of Net Worth certified by Certified Public
Accountant (Annex A)
Purpose: To prove the availability of properties to
cover for the
obligation
IV
Defendants reserves the right to present additional
documentary evidence and witnesses in the course of the
proceedings.
Respectfully submitted.
Iloilo City, August 15, 2015
MARY GRACE E. SEVILLA
Counsel for the Defendant
SEVILLA BERAYE AND ASSOCIATES
Second Floor, XYZ Building
Rizal St., Iloilo City
Telephone No. (033) 320-42-23
E-mail address: mgesevilla@yahoo.com
IBP No. 0901991/ Jan. 10, 2016/ Iloilo City
PTR No. 9903941/ Jan. 6, 2016/Iloilo City
Roll No. 402901
MCLE COMPLIANCE NO. V-0032014/05-02-14
COPY FURNISHED :
CRIS T. CASIPLE
Counsel for the Plaintiff
CASIPLE PADILLA AND ASSOCIATES
Ground Floor, ATM Building
Jalandoni St., Iloilo City
The foregoing Pre-trial Brief was served by registered
mail, personal service not being practical due to the lack of
messengerial personnel.

REPUBLIC OF THE PHILIPPINES

SIXTH JUDICIAL REGION
REGIONAL TRIAL COURT
ILOILO CITY
BRANCH 1
JUAN DE LA CRUZ,
04-235
Plaintiff,
Money with

Civil Case No.

For:

Sum

Prayer
Preliminary
-versus-

of
for

Attachment

JOSE DE LA CRUZ,
Defendant.
x----------------------------------x
PLAINTIFFS PRE-TRIAL BRIEF
PLAINTIFF, by counsel and to this Honorable Court,
respectfully submits this Pre-Trial Brief compliance with the
trial courts order dated, August 6, 2015.
I
Plaintiff is willing to enter into an amicable settlement of the
case, under terms and conditions agreeable to both parties
and submit to alternative modes of dispute resolution;
II
Plaintiff admits only admits paragraphs 6 of the answer.
III
Issues to be resolved are the following:
A. Whether or not the demand there is failure on the part of
the defendant
to heed demand of the plaintiff.
B. Whether or not defendant left the Philippines with the
intent to
defraud the plaintiff.
C. Whether or not defendant has sufficient property to cover
his
obligation to the plaintiff.

D.
Whether or not plaintiff is liable for attorneys fees,
litigations expenses and costs.
IV.
The plaintiff intends to present the following Documentary
evidence:
A. Promissory Note (Annex as Exhibit A)
Purpose: To prove that defendant executed the
promissory note and the obligation is genuine.
B. Demand Letter (Annex as Exhibit B)
Purpose: To prove that plaintiff made a written
demand upon the defendant
IV
Plaintiff reserves the right to present additional
documentary evidence and witnesses in the course of the
proceedings.
Respectfully submitted.
Iloilo City, August 15, 2015
CRIS T. CASIPLE
Counsel for the Plaintiff
CASIPLE PADILLA AND ASSOCIATES
Ground Floor, ATM Building
Jalandoni St., Iloilo City
Telephone No. (033) 338-02-43
E-mail address: ctcasiple@yahoo.com
IBP No. 0832091/ Jan. 5, 2016/ Iloilo City
PTR No. 2903941/ Jan. 7, 2016/Iloilo City
Roll No. 392841
MCLE COMPLIANCE NO. V-009324/04-01-14
COPY FURNISHED :
MARY GRACE E. SEVILLA
Counsel for the Defendant
SEVILLA BERAYE AND ASSOCIATES
Second Floor, XYZ Building
Rizal St., Iloilo City
The foregoing Pre-trial Brief was served by registered
mail, personal service not being practical due to the lack of
messengerial personnel.