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Written Interrogatories

This document contains written interrogatories from plaintiffs Sps. Maximo Tan, Jr. and Casilda Tan directed at Lizel S. Bacalla regarding a civil case filed for annulment of a real estate mortgage and injunction against Philippine Business Bank. The interrogatories seek to confirm details of a letter from PBB accepting a payment proposal from plaintiffs, the deposit of payment to Casilda Tan's account, and PBB's decision to not accept payment and credit the amount back to the account. The interrogatories are submitted by plaintiffs' counsel and a copy is furnished to defendant's counsel.

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199 views3 pages

Written Interrogatories

This document contains written interrogatories from plaintiffs Sps. Maximo Tan, Jr. and Casilda Tan directed at Lizel S. Bacalla regarding a civil case filed for annulment of a real estate mortgage and injunction against Philippine Business Bank. The interrogatories seek to confirm details of a letter from PBB accepting a payment proposal from plaintiffs, the deposit of payment to Casilda Tan's account, and PBB's decision to not accept payment and credit the amount back to the account. The interrogatories are submitted by plaintiffs' counsel and a copy is furnished to defendant's counsel.

Uploaded by

marvilie serna
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

Republic of the Philippines

REGIONAL TRIAL COURT OF NEGROS ORIENTAL


Seventh Judicial Region
BRANCH 42
DUMAGUETE CITY

SPS. MAXIMO TAN, JR. and CIVIL CASE NO. 2021-15919


CASILDA TAN, as represented
by their attorney-in-fact, MIBEN FOR: ANNULMENT OF REAL
LORDITO D. DEGUIT, ESTATE MORTGAGE and
Plaintiffs, INJUNCTION WITH PRAYER
FOR TEMPORARY
---versus---
RESTRAINING ORDER AND
DAMAGES
PHILIPPINE BUSINESS
BANK, INC. HEAD OFFICE
and PHILIPPINE BUSINESS
BANK, INC. DUMAGUETE
BRANCH
Defendants.

RTC NEGROS ORIENTAL


OFFICE OF THE CLERK OF
COURT AND EX-OFFICIO
SHERIFF
Nominal Party
X- - - - - - - - - - - - - - - - - - - - - - - /

WRITTEN INTERROGATORIES
TO: LIZEL S. BACALLA
FROM: SPS. MAXIMO TAN, JR. and CASILDA TAN, as represented
by their attorney-in-fact, MIBEN LORDITO D. DEGUIT, Plaintiffs

Pursuant to Section 1, Rule 25 of the Revised Rules of Court, we


are respectfully requesting you to answer the interrogatories
contained herein within a period of fifteen (15) days from your
receipt hereof with the following instructions:

a. Your response shall be made in writing and shall be signed


and sworn by you;
b. To reiterate, you shall file and serve a copy of your answers
within fifteen (15) days after your receipt thereof;

INTERROGATORIES

1. What is your full name, age, civil status, and current


residence?

2. Defendant Philippine Business Bank wrote a letter dated July


30, 2020 to Plaintiffs, with the heading “Subject: Undertaking
and Acknowledgement Receipt”. Do you confirm this?

3. Would you confirm that per the stated letter, Defendant PBB
accepted the proposal of Plaintiffs which are as follows:

4. Would you confirm that Plaintiffs deposited the payment of


(Php 21, 807, 452.37) to Petitioner Casilda Tan’s PBB account
pursuant to Defendant PBB’s acceptance of the
abovementioned proposal?

5. Would you confirm that Defendant PBB changed its mind and
decided not to accept the payment and consequently hold the
subject titles since they now seek full payment of the entire
obligation of Plaintiffs?

6. Would you confirm that after debiting Plaintiffs’ payment,


Defendant credited it back to Plaintiff Casilda Tan’s PBB
account?

08 August 2022, in Dumaguete City, Philippines.

RESPECTFULLY SUBMITTED.

MERCADO & PARTNERS LAW FIRM


[For Plaintiffs]
Suite 1, 2ND Floor, RM Building
North National Highway cor. East Rovira Road
Dumaguete City

Page 2 of 3
Telephone Number 225-5079/422-7253
rmlawfirm@gmail.com/rjam@mercado-partnerslaw.com

by:

ATTY. RAYMUND J. A. MERCADO


PTR NO. 3081425-01/02/2022
IBP LIFETIME NO. 01108
All Issued in Dumaguete City, Philippines
6th MCLE Compliance No. 431/08-18-2016
Roll No. 35548/ 4-28-1989

and

ATTY. MARVILIE M. SERNA


PTR NO. 3081426-01/03/2022
IBP NO. 201985-02/19/2022
All Issued in Dumaguete City, Philippines
MCLE Compliance No. IV-0029154
Roll No. 70642 (06/04/18)

Copy furnished:

ATTY. RICHARD CATACUTAN


Counsel for Defendant
Dumaguete City

Page 3 of 3

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