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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 Attorney’s
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.

How much was the monthly rate for the said lease? 9. and making the affidavit. b. What are these documents? Can you identify each of these documents? 14. address and the percentage of ownership interest of each owner. 16. 15. Did defendant ever fail to pay on time? . Please state the name. What are the terms of the rental agreement? 10. Interrogatories 1. state the name. the parties. his attorneys. State the names and addresses of all persons who have knowledge of the facts. When is the expiration of the said Contract of Lease? 8. addresses and the date that part of agreement was made. state the name/s if said person/s. Davao del Sur? 7. Is plaintiff an owner of the RENTAL UNIT? 3. Are there any rental units on the property? 5. law firm address and your relationship with the person who helped you in the preparation of this document. the date when he started to manage or maintain the said property. and the source of his information. representatives and. Has any person acting on plaintiff’s behalf been responsible for any aspect of managing or maintaining the property? If so. state the names. When was your last payment made? 11. State each part of the agreement which was not reduced into writing. Since when did you (defendant) start to occupy the said property? 6. Are you still occupying the said lot located at 123 Brgy. d) The pronoun “you” refers to the party whom these Interrogatories are addressed. and that person’s responsibilities. Digos. How did the owner recognize your payment? 12. address.c) Where knowledge of information or possession of a party is requested. his address. For each agreement alleged in the pleadings: a. San Jose. When answer is made by a public or private corporation or a partnership or association. What proof do you have to verify your agreement with the plaintiff? 13. 2. unless privileged. such request includes knowledge of the party’s agents. Does the plaintiff share the ownership? If so. and the persons mentioned in clause (c). 4. and title of the person supplying the information.

how much is the rent increase? 20. JULIA BARETTO Counsel for the plaintiff Suite 123 Don Santiago Bldg. 2011 Tel. 17. April 4. How and when was the defendant notified of the said increase? 22. Since the beginning of defendant’s tenancy. 553-1234 . identify the agreement which was breached. If yes. If yes. ATTY. 24. If yes. state the date and the amount of any late charge. 2635. Philippines. 2017. Why did you not leave the premises even after the expiration of the Contract of Lease? Digos City. 18. What are the reasons for the said increase? 21. 9273382/01-18-12/Digos MCLE NO. Tres de Mayo. 0091212/ 01-6-12 PTR NO. February 15. has plaintiff ever raised the rent? 19. for each late payment. Does the complaint allege a violation of a term of the lease agreement. other than non-payment of the rent? 23. NO. Digos City IBP NO.