Republic of the Philippines

First Judicial Region

REGIONAL TRIAL COURT
Branch 66
San Fernando City, La Union

HEIRS JUAN SARANQUIN, ET AL.,

Plaintiffs,

-versus- CIVIL CASE NO. 9293

For: Recovery of Possession,
Partition and Damages

EMILIA S. GLIAM, ET AL.,

Defendants.
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AMENDED PRE-TRIAL BRIEF

FOR THE DEFENDANTS

DEFENDANTS, through counsel, respectfully submit their amended

pre-trial brief, to wit:

1. POSSIBILITY OF AMICABLE SETLEMENT

Defendants are amenable to enter into an amicable settlement with

the plaintiffs under just and reasonable terms and conditions that are not
contrary to law, morals and public policy.

2. BRIEF STATEMENT OF DEFENDANTS’ CLAIM

 Defendants have lawfully acquired the portions of the subject lots
which they presently occupy and where some of them had erected their
respective house. They have been in possession thereof for many years
now in the concept of owners.

3. STIPULATIONS AND ADMISSION OF FACTS

3.1. Plaintiffs are not the real parties-in-interest;

3.2. Maria Saranquin died single and without issue in 1954;
3.3. Defendants have been in possession in the concept of owners
portions of the subject lands;
3.4. Defendant Emilia S. Gliam’s house is not located within any of
the subject lots; and
3.5. The decision referred to in the complaint was never
implemented/enforced.

4. DOCUMENTARY EXHIBITS FOR DEFENDANTS

Exhibit 1 - Property Record Form - ARP No. 039-01720 in

the name of Feliza Saranquin.

Exhibit 1A - Property Record Form - ARP No. 039-00177 in

the name of Feliza Saranquin.

Exhibit 1B - Tax declaration No. 93-039-17703-A in the name

of Feliza Saranquin.

Exhibit 1C - Tax Declartion No. 93-039-17704-R in the name

of Feliza Saranquin.

Exhibit 1D - Tax declaration No. 93-039-17705-A in the name

of Feliza Saranquin.
Exhibit 1E - OR No. LU 1825186, 4/30/18 - Emilia Gliam for
Feliza Saranquin.

Exhibit 2 - Property Record Form - ARP No. 039-01719 in

the name of Patrocenia Dhalen.

Exhibit 3 - Tax Declaration No. 93-039-17641 in the name of

Margarita Parpados.

Exhibit 3A - Tax Declaration No. 25333 in the name of

Margarita Parpados.

Exhibit 4 - Tax Declaration No. 2009-15-0039-00335 in the

name of spouses, Rony and Anastacia Renon.

Exhibit 5 - Tax Declaration No. 93-039-17640-A in the name

of Margarita Parpados.

Exhibit 6 - Tax Declaration No. 06302 in the name of Juan

Saranquin.

Exhibit 6A - Tax Declaration No. 16066 in the name of Juan

Saranquin.

Exhibit 6B - Tax Declaration No. 93-039-17710 in the name of

Juan Saranquin.

Exhibit 7 - Special Power of Attorney by Juan Saranquin in

favor of Rogelio Saranquin.

Exhibit 8 - Cancellation and Discharge of Mortgage by the

Community Rural Bank of San Gabriel (L.U.),Inc.

Exhibit 9 - Certification by Community Rural Bank of San

Gabriel (L.U.), Inc., in favor of Felipe Saranquin.
 Defendants also reserve the presentation of additional documentary
evidence in the course of the trial.

5. WITNESSES FOR DEFENDANTS

5.1. Emilia S. Gliam

5.2. Felipe Saranquin
5.3. Teresa S. Lilan
5.4. Eva S. Eslava
5.5. Aida S. Espinosa
5.6. Maurecio Acierto Jr.
5.7. Erlinda Gliam
5.8. Municipal Assessor of San Juan, La Union]
5.9. Provincial Assessor of La Union
5.10. Head of Surveys Division, Records Section of DENR - 1
Land Management Service, San Fernando City, La Union
5.11. Geodetic Engineer, ______________________

Witnesses will testify for at least one hour each to substantiate the
allegations in the answer of the defendants to the complaint, to identify
some documents and to testify on related matters.

Defendants also reserve the presentation of additional witnesses in

the course of the trial.

6. ISSUES

6.1. Whether or not the plaintiffs are the real parties-in-interest.

6.2. Whether or not there are indispensable parties who are not
joined as parties in this case.
 6.3. Whether or not the plaintiffs are entitled to the reliefs prayed for
by them.

6.4. Whether or not the defendants have been in possession of

portions of the subject lots in the concept of owner for a long period of
time ripening to an acquisitive prescription.

7. INTENTION TO AVAIL OF DISCOVERY PROCEDURES OR

REFERRAL TO COMMISSIONERS

Defendants has no intention to avail of discovery procedures for the

moment or to refer the instant case to a commissioner, but reserve the
right to do so when deemed necessary in the course of the trial.

8. APPLICABLE LAWS AND JURISPRUDENCE

Pertinent and applicable provisions of the Civil Code as well as

applicable jurisprudence.

9. TRIAL DATES

Defendants will submit to the proper determination by the

Honorable Court in consultation with the parties and their counsels.

San Fernando City, La Union, December 6, 2018.

REYNALDO M. MOSUELA
JAIME C. GONZALES, JR.
Counsel for the Plaintiffs
NORTESURLU Bldg., Purok 3, Sevilla
San Fernando City, La Union
 By:

JAIME C. GONZALES, JR.

IBP Roll No. 68552; O.R. NO. 2548591, 12/18/2017
PTR No. 1068453, January 3, 2018 (SFLU); TIN No. 102052434
MCLE Compliance(New Lawyer)

COPY FURNISHED: (Personal Service)

ATTY. LOIDA C. MARTIREZ

Leviste Street, Manna Residences

Pagdaraoan, San Fernando City

La Union