Republic of the Philippines

MUNICIPAL TRIAL COURT

BRANCH 5
7th JUDICIAL REGION
Cebu City

Ms. Lyka Laynk, plaintiff Civil Case No. 2

for:Unlawful Detainer

-versus-

Mr. Teodoro Tadle, Defendant

x-----------------------------------------x

WRITTEN INTERROGATORIES

TO: MR. TEODORO TADLE, Defendant

FROM: LYKA LAYNK, 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 two-storey house 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 Leisure
Subdivision, Cebu City?
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 terms 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 verify 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
termination of the Contract of Lease?

Cebu City, Philippines, February 26, 2019.

ALFRED C. GEONZON
Counsel for the Plaintiff
Unit 501 D & C Bldg., Capitol Site Cebu City
Not. Commission No. 084-09
Roll No. 345678
IBP No. 1053070 (Lifetime); Cebu City
PTR No. 7689405/ Jan. 10, 2019; Cebu City
MCLE Compliance No. IV- 0013321 1/27/17 Valid until 4/4/2020
Tel. No. (02)255-1234
Cell Phone No. 09191156578
Email Address: ac_geonzon@gmail.com