Republic of the PhilippinesNational Capital Judicial Region

Municipal Trial CourtAngono, Rizal

RIZAL PROVINCIAL GOVERNMENT, Plaintiff,

-versus- SCA Case No. _______

For: Unlawful Detainer

Fortunato Andaya, Noel Valeriano, Brando Abocatal, Tomas Abocatal, Roque Estornino, Michelle Galising, Evelyn Oňot, Virgilio Pascua, Norma Pensocas, Corazon San Antonio, Jose Rivera, Jojo Rivera,Manuel Rivera, Defendants.

PRE-TRIAL BRIEF

Plaintiff, Rizal Provincial Government (hereinafter

referred to as “RPG” for brevity), through the undersigned

counsel and unto this Honorable Court most respectfully

submits this Pre-Trial Brief, to wit:

AMICABLE SETTLEMENT

Plaintiff is willing to settle the case amicably as long

as the terms thereof are reasonable.

FACTS FOR STIPULATION

Plaintiff, in order to expedite the proceedings of this

case, proposes the following facts for stipulation and/or

submission:

1. Plaintiff is the registered owner of the lot subject matter

of this case;

2. Defendants are presently occupying the lot subject

matter of this case;

3. Defendants, without justifiable reason, continuously

failed and refused to vacate said premises despite notice

to vacate sent to them;

ISSUES

1. Whether or not defendants’ occupancy on the lot subject

matter of this case becomes illegal after their failure to

vacate the same without justifiable reason and despite

notice to vacate?

2. Whether or not defendants are liable for the costs of

litigation.

DOCUMENTS FOR MARKING

Plaintiff would like to propose the markings of the

following documents, to wit:

Exhibit “A”- Resolution No. 083, s. 3012

Exhibit “B”- Tax Declaration No. 01-0005-09999

Exhibit “C”- Transfer Certificate of Title No. 068-

2011007648

Exhibit “D”- SP Resolution No. 142, s. 2012

Exhibit “E”- Demand Letter dated June 28, 2012 for

Tomas Abocatal

Exhibit “E-1”- Signature appearing at the bottom of the

demand letter for Tomas Abocatal

Exhibit “F”- Demand Letter dated June 28, 2012 for

Evelyn Onot

Exhibit “F-1”- Signature and date appearing at the

bottom

of the demand letter for Evelyn Onot

Exhibit “G”- Demand Letter dated June 28, 2012 for

Michelle Galising

Exhibit “G-1”- Signature and date appearing at the

bottom

of the demand letter for Michelle Galising

Exhibit “H”- Demand Letter dated June 28, 2012 for

Jojo Rivera

Exhibit “H-1”- Signature appearing at the bottom of the

demand letter for Jojo Rivera

Exhibit “I”- Demand Letter dated June 28, 2012 for

Virgilio Pascua

Exhibit “I-1”- Signature and date appearing at the

bottom

of the demand letter for Virgilio Pascua

Exhibit “J”- Demand Letter dated June 28, 2012 for

Brando Abocatal

Exhibit “J-1”- Signature appearing at the bottom of the

demand letter for Brando Abocatal

Exhibit “K”- Demand Letter dated June 28, 2012 for

Corazon San Antonio

Exhibit “K-1”- Signature appearing at the bottom of the

demand letter for Corazon San Antonio

Exhibit “L”- Demand Letter dated June 28, 2012 for

Roque Estornino

Exhibit “L-1”- Signature appearing at the bottom of the

demand letter for Roque Estornino

Exhibit “M”- Demand Letter dated June 28, 2012 for

Jose Rivera

Exhibit “M-1”- Signature and date appearing at the

bottom

of the demand letter for Jose Rivera

Exhibit “N”- Demand Letter dated June 28, 2012 for

Manuel Rivera

Exhibit “N-1”- Signature appearing at the bottom of the

demand letter for Manuel Rivera

Exhibit “O”- Demand Letter dated June 28, 2012 for

Noel Valeriano

Exhibit “O-1”- Notation “Refuse to Sign” appearing at

the

bottom of the demand letter for Noel

Valeriano

Exhibit “P”- Demand Letter dated June 28, 2012 for

Fortunato Andaya

Exhibit “P-1”- Notations appearing at the left portion of

the

demand letter for Fortunato Andaya

Exhibit “E-1”-

Plaintiff reserved the right to mark other documents

during the course of trial, if necessitated.

WITNESSES/ AFFIDAVITS

Plaintiff will present/submit the affidavits of the

following:

1. Affidavit of Santiago M. Abrera, President Kapisanan

ng Maybahayan sa Purok 6 & 7 Inc.

2. Affidavit of _______________________ of Rizal Provincial

Government, Server of Demand Letters

Plaintiff reserved the right to present/submit other

witnesses/affidavits during the course of the trial/position

paper, if necessitated.

RESPECTFULLY SUBMITTED.

Antipolo City for Angono Rizal, June 10, 2013

OFFICE OF THE PROVINCIAL LEGAL OFFICERCounsel for the Plaintiff

Rizal Provincial Capitol Bldg.,Circumferential Road Corner P. Oliveros St.,

Brgy. San Roque, Antipolo City 1870

By:

ATTY. ROSELLE ANDALLO RAMILOOIC- Provincial Legal Officer

PTR No. 9611411/ 01-01-13/ RizalIBP No. 882447/ 01-04-13/ Rizal

Roll No. 43742MCLE Compliance No. 111-0020170

By:

ATTY. MARIVIC MORGIA FERUELORoll of Attorney No. 61649

IBP No. 907512/ 01-16-13/ RizalPTR No. 9739131/ 01-30-13/ Rizal

MCLE Compliance: IV-0013224

Copy Furnished:

Atty. Franco Fernandez de GuzmanCerezo and De Guzman Law OfficeCounsel for Jose Rivera, Jojo Rivera and Manuel RiveraNo. 4-C K-9th Street corner Col. Salgado StreetWest Kamias, Quezon City

Fortunato Andaya Noel Valeriano Brando AbocatalTomas Abocatal Roque EstorninoMichelle GalisingEvelyn Oňot Virgilio Pascua Norma Pensocas Corazon San Antonio, Brgy. Mahabang Parang,Angono Rizal