REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

MANILA
BRANCH 14

Ms. John Rodson Tagle,

Plaintiff, Civil Case No.____

-versus- For: Interpleader

Ms. Karla Salamera and Ms. Jennifer Anne Reyes

Defendant,

X__________x

PRE-TRIAL BRIEF

Summary of admitted facts

and proposed stipulation of the facts

COMES NOW, the defendant, Ms. Jennifer Anne Reyes, through the
undersigned counsel and unto this Honorable Court, most respectfully submits his
Pre-Trial brief pursuant to the order of the court, and avers:

Possibility of settlement

Pursuant to Rule 18 of the 1997 Rules of Civil Procedure, defendant,

respectfully submits that the defendant is open to settling this dispute amicably,
subject to a concrete proposal that is fair and reasonable and a reciprocal
manifestation of openness from plaintiff.

II

Proposal for stipulations

 1. That on October 31, 2011 plaintiff and defendant Ms. Ruiz entered
into a contract of lease into a 10 year contract of lease of a property
located at U.N Avenue;
2. Rental fee of P55,000 to be paid to the lessor;
3. On the 8th year of the contract defendant Ms. Reyes alleges that he is
the new owner of the property and the monthly rental should be paid
to her;

4. On October 31, 2018, defendant Ms. Reyes, insisted that he is the

owner of the property and the monthly rental fee should be paid
according to the terms of the contract of lease.

III

Statement of the issue

Whether or not the rental fee of P55,000 should be paid to the

defendant-lessor Ms. Karla Salamera or defendant Ms. Jennifer Anne
Reyes?

IV

Evidence for marking

1. Contract of lease executed between Lessor and lessee as

“ANNEX A”
2. Deed of Absolute Sale executed in favor of Ms. Jennifer
Anne Reyes “ANNEX B”
- The purpose is to prove that Ms. Reyes is the real
owner of the subject property in the case.

RESPECTFULLY SUBMITTED.
 Law Office

Counsel for the plaintiff

Lasengga Building,.

890 U.N Avenue Manila

By:

XXX

IBP NO.987/1-6-14

PTR NO. 4568 /1-23-14

ROLL NO:5679

MCLE NO. 6243 , May 2018

CC.

Atty. Yuri Ann Ruiz

Counsel for the Plaintiff

Atty. Russel Rodriguez

Counsel for the Defendant Karla Salamera

Manila