Beruflich Dokumente
Kultur Dokumente
Plaintiff,
FOR
-versusNOVELYN SUMAKEY,
Defendant.
x-----------------------------------x
CANCELLATION OF SALE
OF PARCEL OF LAND
PRE-TRIAL BREIF
WITH UTMOST DEFERENCE TO THE HONORABLE COURT.
PLAINTIFF, by and through the undersigned counsel, and unto this
Honorable Court, most respectfully submit his pre-trial brief as follows:
POSSIBILITY OF AMICABLE SETTLEMENT
Plaintiff is willing to enter into any amicable settlement provided it is
just and reasonable under the circumstances.
FACTS FOR ADMISSION AND/OR
STIPULATION AND DOCUMENTS
FOR ADMISSION
By way of stipulation, the plaintiff proposes the admissions of the
following:
Plaintiff is the owner of a parcel of land located at #354
Pico, La Trinidad, Benguet and covered by Transfer Certificate of
Title No. 060-20122435467 containing a total area of one
thousand (1,000) square meters, more or less;
Plaintiff and defendant entered into a written agreement
of sale which was Contract to Sell on January 20, 2015;
Despite of demand and sufficient time, defendant did not
comply with the terms and conditions of said contract.
ISSUES TO BE RESOLVED
Whether or not the Contract to Sell entered into by the parties on
January 20, 2015, should be annulled and/or declared null and void?
Who between the parties is entitled to damages?
DOCUMENTARY EXHIBITS
EXHIBIT
A
NATURE OF DOCUMENT
Transfer Certificate of Title No. 06020122435467;
PURPOSE: To prove that the plaintiff is
the owner of the parcel of land.
NOTICE:
The Branch Clerk of Court
Regional Trial Court
Branch 10
La Trinidad, Benguet
Greetings:
Please submit forthwith the foregoing Pretrial Brief to the Honorable
Court upon receipt hereof.
La Trinidad, Philippines, August 31, 2016.
ELMER MONTINO