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Republic of the Philippines

Regional Trial Court


Branch 22
Pagadian City

Maria Banga Makiling,


Petitioner,
Case no.
For: Petition for
issuance of
Protection Order

-versus-

Jose Tadjaw Makiling,


Respondent,
x------------------------------------------x

RESPONDENTS PRE-TIAL BRIEF


Respondent, through undersigned counsel, respectfully submits this
Pre-Trial Brief unto the Honorable Court, in compliance with the trial courts
order.
Amicable Settlement
Respondent is willing to enter into an amicable settlement of the case,
under term and condition agreeable to both parties and submit to alternative
modes of dispute resolution.

BRIEF STATEMENT OF THE CASE


This case is for the issuance of protection order filed by the petitioner
in the above mentioned case. That petitioner is allegedly entitled thereto,
because of the alleged unfounded jealousy of the respondent and
maltreatment of the respondent toward the petitioner.
ADMITTED FACTS

1. That he is the respondent of the above-mentioned case;

2. That respondent ADMITS the contents of paragraph 2, only insofar as


his personal circumstances are concerned of the petition;
3. That he ADMITS the contents of paragraph 3, 4, and 5, insofar as the
allegation of date of marriage, the conjugal home and the children of
the respondent and the petitioner of the petition;

Proposed Stipulation of Facts

Respondent requests that defendant admits the following facts:


1. That the frequent quarrel of the petitioner and respondent was due
to the formers illicit relationship;
2. That the frequent intoxication of the respondent was due to his
knowledge of the illicit relationship;
Issues
1. Whether or not the petition should be granted;
2. Whether or not the petitioner has cause of action to file the petition for
the issuance of the protection order.

List of Witnesses
1. Respondent himself to testify on the materials allegations
2. Sam S. Milba to corroborate the testimony of the respondent on its
material points;
3. Barangay Captain Nasser Cauba to corroborate the testimony of the
respondent on its material points;
4. Barangay secretary of sta. lucia district to corroborate the testimony of
the respondent on its material points;

Reservation

Plaintiff expressly reserves the right to present such additional witnesses


and other exhibits and evidence as the exigencies of the trial may require.
Specific Trial Dates
It is respectfully requested that the trial dates be set during the pre-trial
conference to dates most convenient to this Honorable Court and to all the
parties.

MOST RESPECTFULLY SUBMITTED.


PAGADIAN CITY, Philippines, 27th day of July, year 2013.

Counsel for respondent


COPY FURNISHED by Personal Service:
PROVINCIAL CAPITOL CENTER
PAGADIAN CITY

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