Beruflich Dokumente
Kultur Dokumente
Honorable Court, most respectfully submits the herein Pretrial Brief and avers:
Statement of Facts and of the Case
Plaintiff bought a parcel of land from Vicente Tan of
September 11, 1987 as evidenced by a Deed of Absolute
Sale and the Tax Declaration thereof was transferred in
plaintiffs name under Tax Declaration No. 00000-00001
under Survey No. 1234-A.
1. Plaintiff sold a portion thereof to defendant Pablo Reyes but
the selling price was not even fully paid. However, much to
herein plaintiffs astonishment, in the year 2008, herein
plaintiffs peacefully possession of the remaining portion of
the subject land was threatened when defendants claimed
that they already own the whole parcel of the land in
litigation alleging that they bought it from herein plaintiff
twice. Herein plaintiff was so surprised considering that he
only sold to defendant Pablo Reyes one-half (1/2) portion of
1.
2.
3.
4.
5.
Tax Declaration
Deed of Absolute Sale, dated September 11, 1987;
Certification to File Action;
Sketch Plan;
Other documents
Witnesses to be Presented
1. Plaintiff who will testify as to his allegations in the
complaint and other matters relevant thereof;
2. Geodetic Engineer
3. Two other witnesses
Trail Dates
Trial dates will be agreed upon by the parties subject to
the availability of this Honorable Court.
RESPECTFULLY SUBMITTED.
Maasin City, Southern Leyte,
BOB UY
Counsel for the Plaintiff
MCLE Compliance No. 00000
Issued on 01/01/2008
IBP O.R. No. 0000 dated
12/12/08
PTR No. 00000 dated 01/02/09
Tunga-tunga, Maasin City
Copy Furnished:
ATTY. NEIGH WANG
Counsel for the Defendants
Tagnipa, Maasin City