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Delos Reyes, Mark Erwin W.


1. Mister Maranan, what is the nature of your business? (To know why the plaintiff needs to lease a land/building to the defendant) 2. What is the purpose of leasing a real property? 3. How come did you know that the defendant corporation is engaged in leasing real properties? (To show that there is no personal relation between the plaintiff and the former president) 4. What is the nature of business of the defendant corporation? (To prove that board resolution is not required for the president to enter into a lease contract, since the corporation is engaged in real estate business) 5. Who is the President at the time your contract was perfected? (Teodoro Gonzales) 6. In your agreement, when is the start of the lease contract between you and the defendant corporation? 7. Is there any written contract to prove you transaction? (After the witness replied with yes, the counsel will present the contract) 8. Is this the contract you and former President Teodoro Gonzales entered into? 9. Whose signature is this? (While pointing on the plaintiffs signature) 10. And this signature? (While pointing on the defendants signature) 11. How much is the lease contract cost every month? 12. For how many years? 13. Every time you pay your monthly rentals, are there any document/receipts that the defendant corporation gives you? (For the presentation of official and unofficial receipts issued by Ms. Gonzales) 14. Who is Ms. Gonzales? And what is her position in the company? (To show that the plaintiff knows that Ms. Gonzales is an agent of the defendant corporation) 15. Is this the receipts issued by the defendant corporation to you through Ms. Gonzales? (After the witness replied affirmatively, the counsel will present the receipts) 16. What is the reason why Ms. Gonzales gave you unofficial receipts?

17. Is there any chance that you miss your monthly due with the defendant corporation? (Plaintiff dutifully paid the aforesaid monthly lease) 18. What happened sometime in January 2008? (This is where the corporation refused to accept the payments) 19. What is the reason why the defendant corporation refused to accept the payments? (The defendant corporation wants to increase the rent) 20. Did you allow it? (The plaintiff will reply negatively) 21. Then after that, what happened? (The issuance of the demand letter) 22. Is there any stipulation in the letter that it should be pay and vacate? (To prove that the letter is insufficient to eject the plaintiff) 23. Whose signature is this? (Pointing on the defendant Edmund Gonzales signature) 24. What is the reason why they say that your contract with the defendant corporation is void? 25. Do you have any personal relations with the former President Teodoro Gonzales? 26. You only know him as the president? (To emphasize that the plaintiff is an innocent third person contracting in the agent of the corporation) 27. By any chance did you sign any written instrument besides your contract? (The plaintiff will reply negatively) 28. After they say that your contract with them is void, what happened next? 29. Is this the demand letter you sent to them? 30. After that, what transpired next? (The consignment with the RTC of Makati, to show that there is no breach of the contract) 31. In what court? (To show the jurisdiction) 32. Is there any certification to prove that you consigned the monthly rentals to the said court? (Presentation of Certification from RTC)