Republic of the Philippines

MUNICIPAL CIRCUIT TRIAL COURT

Second Judicial Region
Lagawe-Hingyon, Ifugao Province

BRIAN D. TALIC, CIVIL CASE NO: 582

Plaintiff, For:

Recovery of Possession
-versus- with Damages

WILLIAM B. BALA-OY,
Defendant.
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PRE-TRIAL BRIEF
(for the Plaintiff)

WITH THE HIGHEST RESPECT TO THE HONORABLE

COURT, Plaintiff, through counsel unto this Honorable Court,
respectfully submits this Pre-trial brief and for this purpose, alleges
that:

POSSIBILITY OF AMICABLE SETTLEMENT

Plaintiff is willing to amicably settle the same on just and

equitable grounds.

PROPOSED FACTS FOR ADMISSION

1. Defendant never stayed on the land in dispute.
2. Defendant does not have a house on the land in dispute
3. The land referred to in OCT No. CLOA 32 in the name of
Lorenzo Bala-oy is located at Baludibud, Boliwong, Lagawe,
Ifugao.
4. The adjacent land owners of the land referred to in OCT No.
CLOA 32 were not notified of the survey of the land leading to
the issuance of the OCT No. CLOA 32.
5. The land in the name of Bobobban Lingdi covered by Tax
Declaration A1099 marked as Exhibit 2 is located at Mountain
Province as reflected in said tax declaration.
6. Defendant does not have tax declaration nor a title to the land
in dispute.
7. The land where the old house of defendant stands, as depicted
in the photographs attached, is not included in the land in
dispute.
 DOCUMENTARY EVIDENCE

1. Tax Declaration no. 14078 in the name of Felipe Talic

2. Tax Declarations in the name of Dolores Talic
3. Marriage Certificate of Felipe and Dolores Talic
4. Deed of Sale of the land between Dolores Talic and Brian
Talic
5. Tax Declaration no. ARP no 94-01007-00866 in the name
of Brian Talic.
6. Tax Receipts
7. Realty Tax Clearance
8. Others

ISSUE

1. WHO IS ENTITLED TO LAWFUL POSSESSION OF THE LAND.

2. WHO IS ENTITLED TO DAMAGES

WITNESSES:

1. Roberto Alindayo
2. Pedro Lunag
3. Tomas Balanian
4. Dolores Talic
5. Immihig
6. Donato Pagaddut
7. Others

The witnesses would testify to the ownership and possession

of the land by plaintiff and his predecessors and predecessors-in-
interest.

TRIAL DATES
Plaintiff intends to present seven witnesses and prays for eight
trial dates to present them.

RESPECTFULLY SUBMITTED.

Lagawe, Ifugao Province, this 15th day of May, 2017.

PUBLIC ATTORNEY’S OFFICE

Department of Justice
By:

GERALD B. TAYABAN
OIC-DPA, Public Attorney 111
Lagawe, Ifugao
Copy furnished:

ATTY. Kendall Pung-ao T. Immoliap

Banaue, Ifugao