REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

7TH JUDICIAL REGION
Branch 62, Oslob, Cebu

LAMBERTO S. SENO, Civil Case No. OS-18-284

Plaintiff,
FOR: DECLARATION
-versus- OF NULLITY OF TAX
DECLARATIONS,
MUNICIPALITY OF SAMBOAN, DAMAGES AND
CEBU, ALMA SIBONGA, in her ATTORNEY’S FEES
official capacity as the Provincial WITH PRAYER FOR
Assessor of the Province of Cebu, PRELIMINARY
ERWIN GAMALLO, in his official MANDATORY
capacity as Municipal Assessor of INJUNCTION
the Municipality of Samboan, Cebu.
Defendants.

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1ST SET OF WRITTEN INTERROGATORIES TO DEFENDANT

MUNICIPALITY OF SAMBOAN

To:

Hon. Emerito Calderon

Mayor of Municipality of Samboan
Municipal Hall , Poblacion,
Samboan, Cebu

c/o Atty. Rodrigo L. Urbiztondo

Provincial Legal Office
Capitol Bldg., Capitol Site, Cebu City

As manifested in the Plaintiff’s Pre-Trial Brief, and pursuant to

Rule 25, of the Rules of Court, you are hereby served the following 1 st
set of interrogatories to be answered by you fully and personally in
writing and under oath within fifteen (15) days from service hereof.
The questions that are requested to be answered by you, being the
Municipal Mayor of the defendant Municipality of Samboan, are as
follows:
 1. Do you know if your predecessor, former Mayor Raymond
Calderon, who happens to be your son, have ever summoned
plaintiff or his wife, trying to convince them vacate Lot 12025 located
in San Sebastian, Samboan, Cebu?

2. Do you know if your predecessor, former Mayor Raymond

Calderon, who happens to be your son, have ever summoned any
occupant of Lot 12025 to sign any document promising to vacate said
lot otherwise they will not be granted business permit or if they had
already a business permit, their permits will not be renewed?

3. Do you know if your predecessor, former Mayor Raymond

Calderon, who happens to be your son, have ever summoned
plaintiff or his wife, trying to convince the vacate Lot 12027?

4. Do you know if your predecessor, former Mayor Raymond

Calderon, who happens to be your son, have ever summoned any
occupant of Lot 12027 to sign any document promising to vacate said
lot otherwise they will not be granted business permit or if they had
already a business permit, their permits will not be renewed?

5. Have you ever summoned any occupant of Lot 12025 and Lot
12027 for them to sign any document promising to vacate said
parcels of land otherwise they will not be granted business permits or
if they had already a business permit, their permits will not be
renewed?

6. Will the defendant admit that the fence it erected was meant
to encircle the Lot No. 12025 and Lot 12027?

7. Will the defendant admit that the said perimeter fence has
also blocked road lot which is owned by the national government
which separated Lot 12025 and Lot 12027?

8. Will the defendant admit that in the complaint in Civil Case

No. 139-SM, Tax Declaration No. 36-0013-10047 was one of its
annexes?

9. Will the defendant Tax Declaration No. 36-0013-10047 was

the main evidence of the defendant’s claim of ownership over Lot
12025.

10. Aside from the Tax Declarations, what other evidence does
the defendant have, if any, as proof of its ownership over Lot 12025
located in San Sebastian, Samboan, Cebu?

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 11. Does the defendant have any Tax Declaration covering Lot
12025 prior to 2002?

12. Does Tax Declaration No. 013610567 actually exist?

13. Was there any Tax Declaration covering what is now Lot
12025 for the years prior to 2002?

Plaintiff reserves the right to ask further questions by way of

supplemental written interrogatories depending on the answers of
the defendant of the foregoing questions.

August 14, 2018, Cebu City, Philippines.

VERANO LAW OFFICE

F. Martir St.., Lapu-Lapu City, Cebu

By:

ATTY. SAMUEL C. VERANO

Roll No. 56351
Lapu-Lapu City, Cebu
PTR No. 6706259, 1-08-2018 Lapu-Lapu City, Cebu
IBP No. 00159, 1-08-2018, Cebu Chapter
MCLE Compliance No. IV-0003629

Copy furnished:

Atty. Rodrigo L. Urbiztondo

Provincial Legal Office
Capitol Bldg., Capitol Site, Cebu City

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