Scribd Logo
Upload

Welcome to Scribd!

  • 572 views

    Pre Trial Brief Respondent

    Uploaded by

    Wilven Angeles Sinlao
    This document is the respondent's pre-trial brief in a case filed by Wilma Sinlao-Liquiran for the judicial declaration of nullity of marriage from Marko A. Liquiran. [1] The respondent is willing to enter into an amicable settlement. [2] The respondent admits some facts from the petition including the de-facto separation. [3] The respondent proposes additional stipulated facts regarding the petitioner's drug addiction causing issues at home. [3] The issues are whether the petition should be granted and if the petitioner has cause of action. [4] The respondent lists documentary evidence including drug test results and an incident report regarding the petitioner's intoxication, as well

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Pre Trial Brief Respondent

    Uploaded by

    Wilven Angeles Sinlao
    572 views5 pages
    This document is the respondent's pre-trial brief in a case filed by Wilma Sinlao-Liquiran for the judicial declaration of nullity of marriage from Marko A. Liquiran. [1] The respondent is willing to enter into an amicable settlement. [2] The respondent admits some facts from the petition including the de-facto separation. [3] The respondent proposes additional stipulated facts regarding the petitioner's drug addiction causing issues at home. [3] The issues are whether the petition should be granted and if the petitioner has cause of action. [4] The respondent lists documentary evidence including drug test results and an incident report regarding the petitioner's intoxication, as well

    Original Description:

    Pre-trial Brief of petitioner and respondent

    Original Title

    PRE-TRIAL-BRIEF-RESPONDENT

    Copyright

    © © All Rights Reserved

    Available Formats

    DOCX, PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    This document is the respondent's pre-trial brief in a case filed by Wilma Sinlao-Liquiran for the judicial declaration of nullity of marriage from Marko A. Liquiran. [1] The respondent is willing to enter into an amicable settlement. [2] The respondent admits some facts from the petition including the de-facto separation. [3] The respondent proposes additional stipulated facts regarding the petitioner's drug addiction causing issues at home. [3] The issues are whether the petition should be granted and if the petitioner has cause of action. [4] The respondent lists documentary evidence including drug test results and an incident report regarding the petitioner's intoxication, as well

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    572 views5 pages

    Pre Trial Brief Respondent

    Uploaded by

    Wilven Angeles Sinlao
    This document is the respondent's pre-trial brief in a case filed by Wilma Sinlao-Liquiran for the judicial declaration of nullity of marriage from Marko A. Liquiran. [1] The respondent is willing to enter into an amicable settlement. [2] The respondent admits some facts from the petition including the de-facto separation. [3] The respondent proposes additional stipulated facts regarding the petitioner's drug addiction causing issues at home. [3] The issues are whether the petition should be granted and if the petitioner has cause of action. [4] The respondent lists documentary evidence including drug test results and an incident report regarding the petitioner's intoxication, as well

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 5

    REPUBLIC OF THE PHILIPPINES

    REGIONAL TRIAL COURT

    First Judicial Region

    Branch 1

    San Carlos City, Pangasinan

    Wilma Sinlao-Liquiran,
    Petitioner,
    CIVIL CASE NO.
    2022-01-05
    -versus- For:
    JUDICIAL DECLARATION
    OF NULLITY OF MARRIAGE

    Marko A. Liquiran,
    Respondent,
    x------------------------------------------x

    RESPONDENT’S PRE-TIAL BRIEF

    Respondent, through undersigned counsel, respectfully submits this


    Pre-Trial Brief unto the Honorable Court, in compliance with the trial
    court’s order.

    Amicable Settlement

    Respondent is willing to enter into an amicable settlement of the case,


    under term and condition agreeable to both parties and submit to alternative
    modes of dispute resolution.

    BRIEF STATEMENT OF THE CASE

    This case is for the judicial declaration of nullity of marriage filed by


    the petitioner in the above mentioned case. That petitioner is allegedly
    entitled thereto, because of the alleged psychological incapacity of the
    respondent.
    ADMITTED FACTS

    1. That he is the respondent of the above-mentioned case;


    2. That respondent ADMITS the contents of paragraphs 3, 4, 5, 6, 7 and
    8 only insofar as his personal circumstances are concerned of the
    petition;
    3. That he ADMITS the contents of paragraph 10 insofar as the allegation
    of de-facto separation is concerned.

    Proposed Stipulation of Facts

    Respondent requests that petitioner admits the following facts:

    1. That the main reason the respondent left the conjugal home was
    due to the petitioner’s drug addiction;

    2. That the frequent intoxication of the petitioner got out of hand


    which resulted to respondent and their two children sleepless
    nights, anxiety, depression, and mental anguish.

    Issues

    1. Whether or not the petition should be granted;

    2. Whether or not the petitioner has cause of action to file the petition
    for the declaration of nullity of marriage.

    List of Documentary Evidence

    1. Drug Test result of the petitioner ----Exhibit "A"

    2. Incident report form due to the petitioner’s frequent intoxication


    ----Exhibit "B”

    List of Witnesses

    1. Respondent himself to testify on the materials allegations

    3. Barangay Captain Moses Escano to corroborate the testimony of


    the respondent on its material points;

    4. Barangay Secretary of Brgy. Turac, San Carlos City to corroborate the


    testimony of the respondent on its material points;
    Reservation

    Plaintiff expressly reserves the right to present such additional witnesses


    and other exhibits and evidence as the exigencies of the trial may require.

    Specific Trial Dates

    It is respectfully requested that the trial dates be set during the pre-
    trial conference to dates most convenient to this Honorable Court and to
    all the parties.

    MOST RESPECTFULLY SUBMITTED.

    SAN CARLOS CITY, Philippines, 6th day of June, year 2022.

    Basa and Associates Law Offices


    Counsel for Respondent
    148 Brgy. Tebag,
    San Carlos City,
    Pangasinan
    IBP No. 131232 dtd. 01-07-21
    San Carlos City
    PTR No. 342423 /01/14/09
    San Carlos City
    MCLE Compliance II – 0009312
    Dtd. March 30, 2021

    Copy furnished:
    Office of the City Prosecutor ------------------- Personal Service
    San Carlos City, Pangasinan

    Office of the Solicitor General ----------Registered Mail w/ Return Card


    123 Quezon Boulevard
    San Carlos City, Pangasinan
    A
    B.

    You might also like