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Pre-Trial Brief For Defendants

This document is a pre-trial brief submitted by the defendants Danilo L. Viovicente and Alice H. Viovicente in the civil case of Spouses Teodorico Viovicente and Dominga Viovicente versus Spouses Danilo L. Viovicente and Alice H. Viovicente, The Register of Deeds Calamba, Laguna. The brief outlines that an amicable settlement is unlikely, presents facts for admission, identifies the main issue as the validity of the deed of sale, lists exhibits and witnesses to be presented, cites applicable laws, and provides available trial dates.

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154 views2 pages

Pre-Trial Brief For Defendants

This document is a pre-trial brief submitted by the defendants Danilo L. Viovicente and Alice H. Viovicente in the civil case of Spouses Teodorico Viovicente and Dominga Viovicente versus Spouses Danilo L. Viovicente and Alice H. Viovicente, The Register of Deeds Calamba, Laguna. The brief outlines that an amicable settlement is unlikely, presents facts for admission, identifies the main issue as the validity of the deed of sale, lists exhibits and witnesses to be presented, cites applicable laws, and provides available trial dates.

Uploaded by

CJ Mel
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGONAL TRIAL COURT


4th
Judicial Region
Branch ___, Laguna

SPOUSES TEODORICO Civil Case No. _______________


VIOVICENTE and DOMINGA
VIOVICENTE
Plaintiffs, For: Cancellation of Transfer Certificate of Title and
Deed of Absolute Sal

Versus

SPOUSES DANILO L. VIOVICENTE


and ALICE H. VIOVICENTE, THE
REGISTER OF
DEEDS CALAMBA, LAGUNA,
Defendants
x--------------------------x

PRE-TRIAL BRIEF FOR THE DEFENDANTS

COME NOW, the defendants Danilo L. Viovicente and Alice H. Viovicente, by the
undersigned counsel and unto this Honorable Court, most respectfully submits their Pre-Trial Brief,
as follows:

I. POSSIBILITY OF AMICABLE SETTLEMENT


Amicable settlement is highly improbable.
II. FACTS PROPOSED FOR ADMISSION
A.) That that the plaintiffs were not coerced to sign the Deed of Sale dated June 24,
1993
B) That they are the same person who signed any Deed of Sale dated December 14,
1995
c) That they gave the consideration amounting to P 111,180.00 specified therein.
III. ISSUES TO BE RESOLVED
1. Whether or not the subject deed of sale is valid
IV. LIST OF EXHIBITS/DOCUMENTS TO BE MARKED

The defendants will present the following documents with reservation to present
additional documentary evidences—

1
EXHIBIT Nature of Documents
A December 14, 1995 notarized Deed of Sale
B TCT No. 264547
C Judicial Affidavit of NBI Senior Document Examiner Noel Cruz
D Judicial Affidavit of GSIS Chief of the Accounts Administrative
Division Gavino B. Gagarin

V. WITNESSES TO BE PRESENTED

The defendants will present the following witnesses with reservations to present
additional witnesses-
a) The defendants Danilo L. Viovicente and Alice H. Viovicente
b) NBI Senior Document Examiner Noel Cruz

VI. APPLICABLE LAWS and JURISPRUDENCE

Laws on Sales and other pertinent laws.

VI. AVAILABLE TRIAL DATES OF COUNSEL TO COMPLETE EVIDENCE


PRESENTATION

Subject to the court calendar and the availability of the parties.

Other relief are just and equitable under the premises are likewise prayed for.

Calamba, Laguna, Philippines, January 26 , 2003.

ATTY. PEDRO B. GARCIA


Counsel for the Plaintiff
c/o BAM and Associates Law Firm
Luzon Building, Calamba, Laguna
IBP No. 957815/ 1-05-03/ Calamba, Laguna
PTR No. 6130933// 1-08-03/ Calamba, Laguna
Roll No. 77777
MCLE Compliance No. IV-0069752/
March 21, 2003
Telephone No. (082) 285-7717
cc:

1. ATTY. JUANA A. DELA CRUZ


Counsel for the Plaintiffs
Calamba Laguna

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