Republic of the Philippines

REGIONAL TRIAL COURT

9th Judicial Region, Branch 16
City of Zamboanga

CHRISTOPHER SARSOZA,
Plaintiff,
-versus-

CIVIL CASE NO. 0029CA

For: Reconveyance and Damages

AMERKHAN A. SARSOZA
JUNNIELLE MAE BUE,
Defendant.
x-------------------------------------------x

PRE-TRIAL BRIEF FOR THE DEFENDANTS

COME NOW, AMERKHAN A. SARSOZA AND JUNNIELLE MAE
BUE the defendants, 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 defendant Amerkhan Sarsoza is one of the

signatories of the Deed of Sale.

B)

That the defendant Junnielle Mae Bue paid P1,000,000.00 to

Froilan Sarsoza as the total consideration of the lot.

III.

ISSUES TO BE RESOLVED
1. Whether or not the defendants fraudulently deprived the
plaintiff his share in the subject property.

IV.

LIST OF EXHIBITS/DOCUMENTS TO BE MARKED

The plaintiff will present the following documents with
reservation to present additional documentary evidences
EXHIBIT

Nature of Documents

Affidavit of Atty. Arianne A. Fabella

Questioned Document Report of Bonifacio

Araas

Judicial Affidavit of Amerkhan Sabdula

Judicial Affidavit of Junnielle Mae Bue

Judicial Affidavit of Atty. Arianne A. Fabella

Judicial Affidavit of Bonifacio Araas

V.

WITNESSES TO BE PRESENTED
Plaintiff will present the following witnesses with reservations to
present additional witnessesa)

The defendants Amerkhan Sabdula and Junnielle Mae

Bue;

b)

Atty. Arianne A. Fabella, the notary public, to testify

regarding the regularity of the execution of the Deed of
Sale;

c)

Bonifacio Araas, document examiner to testify the

genuineness and authenticity of the signatures of Froilan
Sarsoza and Rachel Sarsoza in the Deed of Sale;

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.
City of Zamboanga, Philippines, February 20, 2015.

ATTY. MARIELLE SAWBAN

Counsel for the Respondent
4A Macrohon Building
Campaner Street, Zamboanga City
PTR No.67472, 01-14-10
IBP OR. No. 98087, 01-14-10
Roll No. 69076
MCLE Cert. No. 0987
(062)955-0683/09088133730
msawban@gmail.com
cc:
1.

Atty. Arnu Mackling

Counsel for the Petitioner
Zamboanga City