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Republic of the Philippines

REGIONAL TRIAL COURT


BRANCH 20
XITH JUDICIAL REGION
Digos City, Davao del Sur, Philippines

MS. KATHRYN BERNARDO


Plaintiff,
- versus - CIVIL CASE NO. 1234567890
For: Unlawful Detainer,
Damages and Attorneys
Fees

MR. DANIEL PADILLA


Defendant
x- - - - - - - - - - - - - - - - - - - - - - x

WRITTEN INTERROGATORIES

TO: MR. DANIEL PADILLA, Defendant


FROM: KATHRYN BERNARDO, Plaintiff

Instructions
Pursuant to Rule 25 of the Rules of Court, you are requested
to answer within fifteen (15) days the following interrogatories.

a) In accordance with Rule 25 Section 2, your response shall be


answered fully in writing and shall be signed and sworn by you.

b) Also in accordance with Rule 25 Section 2, you shall file and serve
a copy of the answers within fifteen (15) days after service
thereof, unless the court on motion and for good cause shown,
extends or shortens the time.

c) If in answering these interrogatories, you encounter any


ambiguities in construing a question, instruction, or definition, set
forth the matter deemed ambiguous and the construction used in
writing.

Definitions
a) Where the name or identity of a person is requested, please state
the full name, home address, and also business address, if
known.

b) Unless otherwise indicated, these Interrogatories refer to time,


place, and circumstances of the occurrence mentioned or
complained of in the pleadings.
c) Where knowledge of information or possession of a party is
requested, such request includes knowledge of the partys agents,
representatives and, unless privileged, his attorneys. When
answer is made by a public or private corporation or a partnership
or association, state the name, address, and title of the person
supplying the information, and making the affidavit, and the
source of his information.

d) The pronoun you refers to the party whom these Interrogatories


are addressed, and the persons mentioned in clause (c).

Interrogatories

1. Please state the name, law firm address and your


relationship with the person who helped you in the
preparation of this document.
2. Is plaintiff an owner of the RENTAL UNIT?
3. Does the plaintiff share the ownership? If so, state the
names, address and the percentage of ownership
interest of each owner.
4. Are there any rental units on the property?
5. Since when did you (defendant) start to occupy the
said property?
6. Are you still occupying the said lot located at 123 Brgy.
San Jose, Digos, Davao del Sur?
7. When is the expiration of the said Contract of Lease?
8. How much was the monthly rate for the said lease?
9. What are the terms of the rental agreement?
10. When was your last payment made?
11. How did the owner recognize your payment?
12. What proof do you have to verify your agreement
with the plaintiff?
13. What are these documents? Can you identify each
of these documents?
14. For each agreement alleged in the pleadings:
a. State each part of the agreement which was not
reduced into writing, the parties, addresses and
the date that part of agreement was made.
b. State the names and addresses of all persons who
have knowledge of the facts.
15. Has any person acting on plaintiffs behalf been
responsible for any aspect of managing or maintaining
the property? If so, state the name/s if said person/s,
his address, the date when he started to manage or
maintain the said property, and that persons
responsibilities.
16. Did defendant ever fail to pay on time?
17. If yes, state the date and the amount of any late
charge, for each late payment.
18. Since the beginning of defendants tenancy, has
plaintiff ever raised the rent?
19. If yes, how much is the rent increase?
20. What are the reasons for the said increase?
21. How and when was the defendant notified of the
said increase?
22. Does the complaint allege a violation of a term of
the lease agreement, other than non-payment of
the rent?
23. If yes, identify the agreement which was
breached.
24. Why did you not leave the premises even after the
expiration of the Contract of Lease?

Digos City, Philippines, February 15, 2017.

ATTY. JULIA BARETTO


Counsel for the plaintiff
Suite 123 Don Santiago Bldg.
Tres de Mayo, Digos City
IBP NO. 0091212/ 01-6-12
PTR NO. 9273382/01-18-12/Digos
MCLE NO. 2635, April 4, 2011
Tel. NO. 553-1234

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