BEA JAMAICA MACATANGAY
Republic of the Philippines
REGIONAL TRIAL COURT
BRANCH 18
XITH JUDICIAL REGION
Digos City, Davao del Sur, Philippines
MS. MAINE MENDOZA
Plaintiff,
- versus - CIVIL CASE NO. 1234567890
For: Unlawful Detainer, Damages
and Attorney’s Fees
MR. ALDEN RICHARDS,
Defendant.
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WRITTEN INTERROGATORIES
TO: MR. ALDEN RICHARDS, Defendant
FROM: MAINE MENDOZA, 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 party’s 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 plaintiff’s 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 person’s 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 defendant’s 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, December 29, 2017.
ATTY. LOLA DORA
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
