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REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES


Second Judicial Region
Cauayan City, Isabela
NILO LOCO
Plaintiff,
CIVIL CASE No. 12345
FOR: Unlawful Detainer

-versusMANDO RUGAS
Defendant.
x-----------------------------------x

PLAINTIFFS PRE-TRIAL BRIEF


PLAINTIFF, by counsel, to this Honorable Court, respectfully submits
the Pre-Trial Brief as follows:
I. WILLINGNESS TO AN AMICABLE SETTLEMENT OF THIS CASE.
Plaintiff is amenable to an amicable settlement of this case.
II. PLAINTIFFS CLAIM
Plaintiff, Nilo Loco, is the owner of a land over which an
apartment had been constructed located at No. 456 Maramag Street,
San Fermin, Cauayan City, Isabela, Philippines. By virtue of a contract
of lease, plaintiff leased to defendant, Mando Rugas, the aforesaid
apartment for a consideration of P5,000.00 a month as rental to be paid
within the first ten (10) days of each month starting August 9, 2013.
Since then, defendant has been religious in paying the rental but
starting November 10, 2014 to present, he failed to pay the agreed
rental. On December 10, 2014, the plaintiff sent a letter of demand to
vacate the apartment which was received by the defendant. But,
despite said letter of demand which was repeated by oral demands,
defendant failed and still refused to pay the agreed amount of rentals
and to vacate the apartment. By reason of failure of the defendant to
vacate the premises and to pay the unpaid rentals, the plaintiff was
compelled to institute this action.
III. FACTS PROPOSED FOR ADMISSION
1. Identity of the apartment.
2. The apartment is owned by plaintiff.

3. Defendant is occupying the apartment by virtue of a contract of


lease for a consideration of P5,000.00 monthly entered into by
plaintiff and defendant.
4. Defendant fails to pay the monthly rental starting November 10,
2014 up to present.
5. Plaintiff sent a letter of demand to vacate the apartment which
was received by defendant.
6. Defendant, despite repeated demands, fail to pay the rental and
vacate the premises.
IV. ISSUE
Whether or not the prevailing party is entitled to attorneys fees
and damages.
V. EXHIBIT
Demand Letter to vacate the apartment dated December 10,
2014.
VI. NUMBER OF WITNESSES
Plaintiff will present 4 or 5 witnesses.
VII.

APPLICABLE LAWS
Laws and jurisprudence for Unlawful Detainer.
Cauayan City, Isabela, March 27, 2015.

Respectfully submitted:

ATTY. AIZA G. ORDOO


Counsel for the Plaintiff
Minante 1, Cauayan City, Isabela
IBP No. 111111
Roll No. 22222
PTR No. 1234567

Copy furnished:
Atty. Elizabeth T. Madamba-Reyes
San Fermin, Cauayan City, Isabela