REPUBLIC OF THE PHILIPPINES

Regional Trial Court

6th Judicial Branch
Branch 43,
Bacolod City
MS. LEIH BAH TON,
Petitioner

CIVIL CASE NO.123456

FOR: Sole Custody of Minor Do Ling Jr.
with prayer for support

-VersusDO M. LING SR.,

Respondent
x --------------------------------------------- x
PRETRIAL BRIEF
RESPONDENT, by counsel, respectfully submits his Pre-Trial Brief, as
follows:

1. Willingness to enter into an amicable settlement and possible terms

of any such settlement
a. Subject to a concrete proposal that is fair and reasonable and a
reciprocal manifestation of openness from Petitioner,
Respondent is open to the possibility of amicably settling this
dispute
b. Respondent respectfully submits that the desired terms of any
amicable settlement would involve the dismissal of the petition
on the ground of lack of cause of action, and the payment of
damages prayed for.

2. Brief statement of claims and defenses

A. Petitioner seeks to have sole custody of their child Do Ling Jr. and
prays for monthly support of P10,000 on the ground that respondent
is said unfit to provide for their child because he is a casino addict
and that he treats his wife and their child poorly and aggressively.
B. Respondent is against claim of petitioner invoking his rights as
father of Do Ling Jr. and that he is willing to provide unlike the
allegations of petitioner but his capability should be taken into
consideration seeing that his only source of income met a financial
crisis and that all allegations against him by petitioner are nothing bu
hearsay.
3. Facts and other matters admitted by the parties
A. That petitioner manages her architectural design and consultancy
firm located at Strawberry St., Bacolod City whole respondent is the
owner of Negros Island Auto Parts located at Kiwi St., Bacolod City.
B. That they were both single when they had their child Do Ling Jr.
and due to their indifferences they did not marry each other.
C. That there was an agreement between them that respondent is
obliged to give P10,000 as monthly support to their child.
4. Issues to be tried
A. Whether or not respondent failed to provide support to their child
B. Whether or not petitioner should be entitled sole custody of Do
Ling Jr. on the ground of the unfitness of respondent Do Ling Sr. as
father.
5. Evidence
a. Respondent intends to present the following witnesses:
Ms. Mayna Bah Ton, petitioners sister to prove that petitioner
had received P3,000 from respondent for their childs monthly
support instead of the required P10,000 due to respondents
financial crisis
Aragid Nah Bah Ton, petitioners brother to testify that
respondent was able to give P5,000 as monthly support for the
meantime that respondents company is crawling back into a
stable status.
Johnny Boy Dee, nephew of respondents wife, to prove that he
was never a bad husband and was not a casino addict and to
testify that he is a person of good moral standing.

6. Resort to Discovery
a. Considering the relatively simple issues presented, Respondent
does not intend to avail of discovery at this time.
b. Subject, however, to a concrete and reasonable request for
discovery from Petitioner, Respondent reserves the right to
resort to discovery before trial.
7. Available Trial Dates
a. March 20-25, 2016 at any day convenient.

RESPECTFULLY SUBMITTED.
March 2, 2016, Bacolod City.
By:
ATTY. KATRINA TAN
Roll No. 98765
IBP No, 12342/1-3-2017/Bacolod
PTR No. 34561/1-3-2017/Bacolod
ATTY. MA. JELA JORBINA
Roll No. 98766
IBP No, 12343/1-3-2017/Bacolod
PTR No. 34564/1-3-2017/Bacolod
ATTY. JOSEPH RENZ SARDON
Roll No. 98767
IBP No, 12345/1-3-2017/Bacolod
PTR No. 34566/1-3-2017/Bacolod

Copy furnished:
ATTY. MARJORIE BRIONES
Counsel for the Plaintiff
Bacolod City
Doc No. 1
Page No. 1

Book No V
Series of 2016