REPUBLIC OF THE PHILIPPINESMUNICIPAL TRIAL COURT IN CITIESSecond Judicial RegionCauayan City, Isabela

NILO LOCOPlaintiff,CIVIL CASE No. 12345-versus-FOR: Unlawful Detainer

MANDO RUGASDefendant.

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PLAINTIFFS PRE-TRIAL BRIEF

PLAINTIFF, by counsel, to this Honorable Court, respectfully submits the Pre-Trial Brief as follows:I. WILLINGNESS TO AN AMICABLE SETTLEMENT OF THIS CASE.Plaintiff is amenable to an amicable settlement of this case.II. PLAINTIFFS CLAIMPlaintiff, Nilo Loco, is the owner of a land over which an apartment had been constructed located at No. 456 Maramag Street, San Fermin, Cauayan City, Isabela, Philippines. By virtue of a contract of lease, plaintiff leased to defendant, Mando Rugas, the aforesaid apartment for a consideration of P5,000.00 a month as rental to be paid within the first ten (10) days of each month starting August 9, 2013. Since then, defendant has been religious in paying the rental but starting November 10, 2014 to present, he failed to pay the agreed rental. On December 10, 2014, the plaintiff sent a letter of demand to vacate the apartment which was received by the defendant. But, despite said letter of demand which was repeated by oral demands, defendant failed and still refused to pay the agreed amount of rentals and to vacate the apartment. By reason of failure of the defendant to vacate the premises and to pay the unpaid rentals, the plaintiff was compelled to institute this action.III. FACTS PROPOSED FOR ADMISSION1. Identity of the apartment.2. The apartment is owned by plaintiff.3. Defendant is occupying the apartment by virtue of a contract of lease for a consideration of P5,000.00 monthly entered into by plaintiff and defendant.4. Defendant fails to pay the monthly rental starting November 10, 2014 up to present.5. Plaintiff sent a letter of demand to vacate the apartment which was received by defendant.6. Defendant, despite repeated demands, fail to pay the rental and vacate the premises.IV. ISSUEWhether or not the prevailing party is entitled to attorneys fees and damages.V. EXHIBITDemand Letter to vacate the apartment dated December 10, 2014.VI. NUMBER OF WITNESSESPlaintiff will present 4 or 5 witnesses.VII. APPLICABLE LAWSLaws and jurisprudence for Unlawful Detainer.Cauayan City, Isabela, March 27, 2015. Respectfully submitted:

ATTY. AIZA G. ORDOOCounsel for the PlaintiffMinante 1, Cauayan City, IsabelaIBP No. 111111Roll No. 22222PTR No. 1234567

Copy furnished:

Atty. Elizabeth T. Madamba-ReyesSan Fermin, Cauayan City, Isabela