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Pre-Trial Brief Rupenta
Pre-Trial Brief Rupenta
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COMES NOW, the undersigned counsel unto this Honorable Court, most
respectfully submits the Defendants Pre-Trial Brief and further states:
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c. The Deed of Extrajudicial Settlement of Estate was registered
with the Registry of Deeds of Digos, Davao del Sur.
d. That the previous title TCT No. T-204718 was cancelled and a
new one was issued in the name of Natividad Samar Ymana
and Cristita Samar Feolog with a TCT No. T-144-2013001091.
f. That the only proof of the alleged ownership of the Plaintiffs over
the above-mentioned property is an unsigned hand-written note
allegedly to be that of Adela Samar.
i. That the Defendants did not know that the property of the
Plaintiffs encroached upon their 2,766 square meter parcel of
land before the Plaintiffs instituted this case.
j. That the Defendants have been paying the real property tax over
the property including the disputed area.
III. ISSUES
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d. WHETHER OR NOT THE PLAINTIFFS SHOULD BE EVICTED FROM
THE 173-SQUARE METER PORTION OF THE PROPERTY SUBJECT
OF THIS CASE
IV. WITNESSES
a. Natividad S. Ymana
b. Cristita S. Feolog
EXHIBIT EVIDENCE
Deed of Extrajudicial Settlement dated
1 October 11, 2012
Transfer Certificate of Title Number T-144-
2 2013001091
Tax Declaration of Real Property (TD No. 11-
3 0018-02533)
Provincial Treasurers Real Property Tax
4 Receipts dated March 22, 2016 worth Php
1,078.92
Provincial Treasurers Real Property Tax
5 Receipts dated March 22, 2016 worth Php
1,213.81
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b. Subject, however, to a concrete and reasonable request for
discovery from the defendants, plaintiffs reserve the right to
discovery before the trial.
Respectfully submitted.
Davao City, ____________, 2017
ATTY.ISRAELITO P. TORREON
Roll No. 42916
IBP No. 977172, 1/7/2016, Digos City
PTR No. 6787035, 1/6/2016, Davao City
MCLE Exemption No. V-0005986, 01/30/2015
Copy furnished:
EXPLANATION
Copies of this Manifestation were served to the parties through registered mail due
to distance, time constraints and lack of personnel to effect personal service.
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