Republic of the Philippines

Municipal Trial Court in Cities

Tacloban City
Branch 1

PEDRO SANTOS,
Plaintiff,
CIVIL CASE No.12345
-versus- FOR: Unlawful Detainer

JUAN CRUZ,
Defendant.

x----------------------------x

PRE-TRIAL BRIEF

DEFENDANT, by counsel, respectfully submits his Pre-Trial

Brief, as follows:

I. WILLINGNESS TO ENTER INTO AN AMICABLE SETTLEMENT

AND POSSIBLE TERMS OF ANY SUCH SETTLEMENT

1. Plaintiff is open to settling this dispute amicably, subject to a

concrete proposal that is fair and reasonable and a reciprocal
manifestation of openness from defendant.

II. BRIEF STATEMENT OF CLAIMS AND DEFENSES

1. The defendant admits that he entered into a contract of lease

with the plaintiff;

2. Defendant raise the defense that the condition precedent

to file a complaint for unlawful detainer has not been
complied with that is, the referral to the Katarungang
Pambarangay.

III. FACTS AND OTHER MATTERS ADMITTED BY THE PARTIES

1. Defendant admits the personal circumstances of the parties as

stated in the compliant and answer.
 2. Defendant further admits the facts stated in his answer only.

IV. ISSUES TO BE TRIED

1. Whether or not the complaint be dismissed on the ground of

failure to comply with the conditions precedent.

V. AVAILABLE TRIAL DATES

The defendant would depend on the dates agreed upon during

the pre-trial.

RESPECTFULLY SUBMITTED.

Tacloban City, July 10, 2019.

ATTY. JOSE RAMOS

Counsel for the Defendant
Roll No. 45678
IBP No. 17493, issued on
January 2015 at Tacloban
City
PTR No. 8719 issued on

COPY FURNISHED:

ATTY. MARIA REYES

Counsel for the Plaintiff
Roll No. 125656
IBP No. 64139, issued
on January 2015 at Tacloban City
PTR No. 3294 issued
on July 2016 at Tacloban City
 EXPLANATION

A copy of this pleading is served via registered mail instead of

personal service on the adverse counsel due to the distance of his
law office address and the lack of field staff of undersigned counsel at
this time.

ATTY. JOSE RAMOS