Civpro Written Interrogatories 112x5o

Republic of the Philippines REGIONAL TRIAL COURT BRANCH 20 XITH JUDICIAL REGION Digos City, Davao del Sur, Philippines MS. KATHRYN BERNARDO Plaintiff, - versus -

CIVIL CASE NO. 1234567890 For: Unlawful Detainer, Damages and Attorney’s Fees

MR. DANIEL PADILLA Defendant x- - - - - - - - - - - - - - - - - - - - - - x WRITTEN INTERROGATORIES TO: MR. DANIEL PADILLA, Defendant FROM: KATHRYN BERNARDO, Plaintiff Instructions Pursuant to Rule 25 of the Rules of Court, you are requested to answer within fifteen (15) days the following interrogatories. a) In accordance with Rule 25 Section 2, your response shall be answered fully in writing and shall be signed and sworn by you. b) Also in accordance with Rule 25 Section 2, you shall file and serve a copy of the answers within fifteen (15) days after service thereof, unless the court on motion and for good cause shown, extends or shortens the time. c) If in answering these interrogatories, you encounter any ambiguities in construing a question, instruction, or definition, set forth the matter deemed ambiguous and the construction used in writing. Definitions a) Where the name or identity of a person is requested, please state the full name, home address, and also business address, if known. b) Unless otherwise indicated, these Interrogatories refer to time, place, and circumstances of the occurrence mentioned or complained of in the pleadings.

c) Where knowledge of information or possession of a party is requested, such request includes knowledge of the party’s agents, representatives and, unless privileged, his attorneys. When answer is made by a public or private corporation or a partnership or association, state the name, address, and title of the person supplying the information, and making the affidavit, and the source of his information. d) The pronoun “you” refers to the party whom these Interrogatories are addressed, and the persons mentioned in clause (c). Interrogatories 1. Please state the name, law firm address and your relationship with the person who helped you in the preparation of this document. 2. Is plaintiff an owner of the RENTAL UNIT? 3. Does the plaintiff share the ownership? If so, state the names, address and the percentage of ownership interest of each owner. 4. Are there any rental units on the property? 5. Since when did you (defendant) start to occupy the said property? 6. Are you still occupying the said lot located at 123 Brgy. San Jose, Digos, Davao del Sur? 7. When is the expiration of the said Contract of Lease? 8. How much was the monthly rate for the said lease? 9. What are the of the rental agreement? 10. When was your last payment made? 11. How did the owner recognize your payment? 12. What proof do you have to your agreement with the plaintiff? 13. What are these documents? Can you identify each of these documents? 14. For each agreement alleged in the pleadings: a. State each part of the agreement which was not reduced into writing, the parties, addresses and the date that part of agreement was made. b. State the names and addresses of all persons who have knowledge of the facts. 15. Has any person acting on plaintiff’s behalf been responsible for any aspect of managing or maintaining the property? If so, state the name/s if said person/s, his address, the date when he started to manage or maintain the said property, and that person’s responsibilities. 16. Did defendant ever fail to pay on time?

17. If yes, state the date and the amount of any late charge, for each late payment. 18. Since the beginning of defendant’s tenancy, has plaintiff ever raised the rent? 19. If yes, how much is the rent increase? 20. What are the reasons for the said increase? 21. How and when was the defendant notified of the said increase? 22. Does the complaint allege a violation of a term of the lease agreement, other than non-payment of the rent? 23. If yes, identify the agreement which was breached. 24. Why did you not leave the premises even after the expiration of the Contract of Lease? Digos City, Philippines, February 15, 2017. ATTY. JULIA BARETTO Counsel for the plaintiff Suite 123 Don Santiago Bldg. Tres de Mayo, Digos City IBP NO. 0091212/ 01-6-12 PTR NO. 9273382/01-18-12/Digos MCLE NO. 2635, April 4, 2011 Tel. NO. 553-1234