REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch , City of____

ANA C. SULEIK , represented herein

by her Attorney-in-Fact,
DR. ANNE MARIE S. YU,
Plaintiff,

-versus- CIVIL CASE NO. Q-10-67202

MAXIMO NARTATEZ, JR.

and all persons claiming rights
under him as lessees, heirs, successors,
assigns, agents and representatives,
herein designated as “JOHN DOES,”
Defendants.
x----------------------------------------------x

TO: MR. MAXIMO NARTATEZ, JR.

No. 19 Hunter St. cor. Camaro St.
Barangay Fairview, Quezon City

WRITTEN INTERROGATORIES

Pursuant to Rule 25 of the Rules of court, plaintiff, by counsel, respectfully serves these Written
Interrogatories on facts both relevant and material to plaintiff’s claims and defendant’s defenses, to be
answered in writing and under oath, within fifteen (15) days from receipt hereof, under pain of the
sanctions found in Rule 29 of the Rules of Court:

Question 1. In paragraph 7 of the Answer with Counterclaim, dated 10 July 2010, defendant
claims that his entry into the subject land started in 1996 or 1997 with the consent and authority of a
certain Segundino Y. Tamayo.
 1.1. Does defendant have any written authority from Segundino Tamayo? If so, please
attach a copy thereof to the answer.

1.2. What does the authority consist in? Did defendant enter the property as a lessee?

1.2.1. Does the authority from Tamayo include constructing structures and
buildings on the property?
1.2.2. If so, when did defendant start constructing the structures now existing on
the properties?

1.2.3. Does defendant have building permits, clearances and other licenses to
construct structures on the subject land? Please attach them to the answer.

1.3. Did defendant pay any rental to Segundino Tamayo from 1996 to 2001? If yes, how
much? Please attach receipts of payment of rentals.

Question 2. In Annex “1” the Answer, defendant alleged that Segundino Tamayo was an heir of
the late Ponciano Padilla Tamayo who executed an affidavit of self-adjudication over the the land covered
by TCT No. 20922.

2.1. Did Segundino Tamayo pay all the taxes (estate tax etc.) relative to the affidavit of self-
adjudication? If so, please provide proof.

2.2 Did Segundino Tamayo post the required bond relative to such self-adjudication? If so,
please provide proof.

2.3. Did Segundino register/transfer the property in his name by paying the necessary
taxes? If so, please provide proof.

2.4. Was a new title cancelling TCT No. 20922 issued in favor of Segundino Tamayo? If so, Commented [MS1]:

please provide a certified true copy.

 Question 3. In paragraph 7 of the Answer, defendant alleged that he bought the subject land from
Segundino Tamayo on February 25, 2001.

3.1. Did defendant pay the capital gains tax and documentary stamp taxes on the said sale?
If yes, please attach the proof of tax payments to the answer.

3.2. Did defendant pay registration and transfer fees on the sale? If so, please attach proof
thereof to the answer.

3.3. Does defendant have any title and tax declaration to the land he allegedly bought? If
so, please produce the title and tax declaration. If not, please produce a document showing that
defendant annotated his land on the title of Segundino Tamayo.

3.4. Who paid the realty taxes on the land from 1996 to the present? Please attach copies
of all the realty tax payments from 1996 to the present.

3.5. Under whose name are the tax declarations on the land from 1996 to the present?
Please produce them and attach them to the answer.

3.6. Before buying the property from Segundino Tamayo in February 2001, did defendant
conduct a relocation survey to determine the metes and bounds of the subject land he was buying?
If so, please attach the said survey.

Question 4. In the Answer with Counterclaim, defendant alleged that the subject land was a
portion of Lot ____under Transfer Certificate No. _____consisting of ______ square meters of land in
Barrio _+__, Municipalities of _____ and _____, Rizal. Please produce a document showing the Lot
__covered by plaintiff’s TCT No. _____ is the same property that was allegedly sold to defendant by
Segundino Tamayo.

Question 5. Defendant has attached to the Answer the Decision in Civil Case No. ____ where Bank
(__) allegedly lost in the Quieting of Titles with Reconveyance of Real Properties. Please attach to the
answer the document showing that the ___ property involved in that case is the same property subject
of the instant case.

5.1. Was that decision annotated on the title or tax declaration pertaining to the lot being
claimed by ___ in that case? If so, please produce a certified true copy of the title or tax
declaration in the name of ___ where the decision was annotated.

Question 6. After the barangay conciliation sometime March 20__, did defendant file any
complaint against ____ or herein plaintiff for the purpose of annulling the sale between them or for the
purpose of annulling ___’s title?

Question 7. In par. 4 of the Answer, defendant admitted constructing his business on the subject
property. When did he start constructing his business? What businesses are these? Please provide the
licenses and other papers pertinent to these businesses.

7.1. Since the establishment of these businesses, how much has defendant earned up to
the present? Please provide all the documents pertaining to the income that defendant has derived
from his businesses on the subject property.

7.2. Who are the current occupants of the subject property? Please identify these people.

7.3. What is the agreement between defendant and the other occupants of the subject
property? If these are lessees, please provide the lease contracts with these occupants.

7.4. If there are lessees on the property, how much is defendant earning as a result of such
lease contracts?

RESPECTFULLY SUBMITTED.

Alaminos City, Pangasinan, for Quezon City, 3 August 20__.

MLAW FIRM
 Counsel for Plaintiff
086 Magsaysay, Alaminos City 2404, Pangasinan
Tel: (075) 5515719
Email: mct@mctamayo.com

By:

MERIAM C. TAMAYO
PTR No. 0042126; Alaminos City; 1/12/10
IBP No. 812267; RSM Chap.; 1/12/10
Roll of Attorneys No.:
MCLE Certificate of Compliance No.

MANIFESTATION

For lack of material time, the foregoing Written Interrogatories was served and filed by registered
mail.

COPY FURNISHED:

ATTY. LEON O. RIDAO R.R. No. _______

Counsel for Defendant Date, 2010
___________St. Sta. Mesa PO
___________, Quezon City MCT

written interrogatories/___