Discovery in general is the disclosure of facts resting in the knowledge of

the defendant, or as the production of deeds in writings, or things in his

possession or power, in order to maintain the right or title of the party
asking it, in a suit or proceeding. (Insular Life Assurance Co. Ltd. vs CA, G.R.
No. 97654, November 14, 1994).

Defendant emphasizes that the purpose of interrogatories to parties

under Rule 25 of the Rules of Court is to allow the party to the action to elicit
material and relevant facts from any adverse party.

An examination of the questions propounded by the plaintiffs in their

Motion generally requests the production of documents, some of which are
not within the possession or control of the Defendant. The requests for the
production of documents under the guise of written interrogatories is
contrary to the established purpose of interrogatories under Rule 25 which
is to obtain FACTS, not documents

Plaintiffs’ Motion to Compel Answer is entirely repetitious. We stress

yet again that the Defendant has already provided all RELEVANT and
MATERIAL facts and information in her responsive pleading that are within
her PERSONAL KNOWLEDGE. Beyond those, she is already incompetent
to answer.

The evident purpose is to enable the parties, consistent with

recognized privileges, to obtain the fullest possible knowledge of the issues
and facts before civil trials. (Republic vs. Sandiganbayan, 204 SCRA 212, 223
[1991])

Considering that there is a pending motion for the dismissal of the

case, the motion is premature at best such that if the court will rule the
dismissal of the instant case,

Discovery in general is the disclosure of facts resting in the knowledge of

the defendant, or as the production of deeds in writings, or things in his
possession or power, in order to maintain the right or title of the party
asking it, in a suit or proceeding. (Insular Life Assurance Co. Ltd. vs CA, G.R.
No. 97654, November 14, 1994).

Defendant emphasizes that the purpose of interrogatories to parties

under Rule 25 of the Rules of Court is to allow the party to the action to elicit
material and relevant facts from any adverse party.
 An examination of the questions propounded by the plaintiffs in their
Motion generally requests the production of documents, some of which are
not within the possession or control of the Defendant. The requests for the
production of documents under the guise of written interrogatories is
contrary to the established purpose of interrogatories under Rule 25 which
is to obtain FACTS, not documents

Plaintiffs’ Motion to Compel Answer is entirely repetitious. We stress

yet again that the Defendant has already provided all RELEVANT and
MATERIAL facts and information in her responsive pleading that are within
her PERSONAL KNOWLEDGE. Beyond those, she is already incompetent
to answer.

The evident purpose is to enable the parties, consistent with

recognized privileges, to obtain the fullest possible knowledge of the issues
and facts before civil trials. (Republic vs. Sandiganbayan, 204 SCRA 212, 223
[1991])

Considering that there is a pending motion for the dismissal of the

case, the motion is premature at best such that if the court will rule the
dismissal of the instant case,