The quick brown fox jumps B.

WILLINGNESS TO ENTER INTO AMICABLE SETTLEMENT

Plaintiffs are open to settlement provided it is on just and reasonable grounds.

C. ADMITTED FACTS

All allegations indicated in the pleadings submitted by the plaintiff.

D. PROPOSED STIPULATIONS OF FACTS

As provided under Rule 26 of the Rule on Civil Procedure, Plaintiff requests defendant to admit the
genuineness and due execution of the following documents within fifteen (15) days after service
thereof, otherwise each of the following documents shall be deemed admitted:

Plaintiff is not willing to consider any amicable settlement or undergo alternative modes of dispute
resolution with respect to the primary prayer of this complaint. However, the plaintiff is open to the
possibility of amicable settlement in relation to the necessary expenses made by the defendant in the
maintenance and preservation of the subject property.

II.
ADMISSIONS TO THE STIPULATION OF FACTS

Plaintiff admits the facts herein presented:

1. Defendant is in physical/actual possession of the subject property;

2. Under paragraph 9.3 of the Answer, as to the death of the primitive owner Mr. Andres Y.
Bonifaquiao but not as to the date of the latter’s death.

III.
ISSUES TO BE TRIED AND RESOLVED

The Plaintiff proposes the following issues to be tried and resolved by this Honorable Court:

1. Whether the defendant’s claim of ownership of the subject property gives him a better right of
possession over the same.

2. Whether the defendant’s legal possession of the Subject Property became illegal upon plaintiff’s
demand to vacate.

3. Whether the award of relief sought by defendant is justified.

IV.
TESTIMONIES AND DOCUMENTS TO BE PRESENTED

Plaintiff will present the following Documentary and Testamentary Evidence:

1. Transfer Certificate of Title No. T-9790 under the name of Marcelo and Corazon de Jesus (Annex
“A”);
2. A copy of the Sketch Plan of the subject property (Annex “B”);
3. Deed of Absolute Sale between Mr. Andres Bonifaquiao and Gabriela Silang to Spouses Marcelo
and Corazon de Jesus (Annex “C”);
4. Tax Declaration No. 0500412 of the Subject Property (Annex “D”);
5. Tax Declaration No. 0500590 of the Subject Property (Annex “E”);
6. Demand Letter to Mr. Antonio Lopez date June 21, 2013 (Annex “F”);
7. Certification to File Action dated October 10, 2013 (Annex “G”);
8. Original Certificate of Title under the name of Mr. Andres Bonifaquiao marked “CANCELLED” by
the Register of Deeds (Annex “H”);
9. Certificate of Death of Mr. Andres Bonifaquiao (Annex “I”);
10. Affidavit of Ms. Andressa Bonifaquiao (Annex “J”);
11. Certificate of Live Birth of Ms. Andressa Bonifaquiao (Annex “K”);
12. Affidavit of Owner of Property adjacent to the Subject Property (Annex “L”);
13. Proof of Delivery or the Return Slip of the delivered Demand Letter dated June 21, 2013 (Annex
“M”).

V.
AVAILABILITY FOR TRIAL

The Plaintiff respectfully informs this Honorable Court of her willingness to proceed to an actual
trial of the case whenever necessary at the convenient time to the parties and the calendar of this
tribunal.