Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
BRANCH ___
Cebu City

LUKE DEIDER

Plaintiff,

-versus- Civil Case No.2017-41

For: COLLECTION OF SUM OF MONEY

SURIGAO ISLAND SALES CORPORATION (SISC), AND

ARIANNE SANTOS,

Defendant,

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WRITTEN INTERROGATORIES

TO: SURIGAO ISLAND SALES CORPORATION (SISC), AND

ARIANNE SANTOS, Defendant

FROM: LUKE DIEDER, Plaintiff

Instructions

Pursuant to Rule 25 of the Rules of Court, you are

requested to answer within fifteen (15) days the following
interrogatories.
 Pursuant to Section 5, Rule 25 of the Rules of Court, in
relation to Section 2, Rule 23 of the same Rules, questions
as to any matters not privileged may be asked as long as it
is relevant to the subject of the pending action.

a) These interrogatories are continuing in character so

as to require you to file supplementary answers if you obtain
further or different information before trial.

b) In accordance with Rule 25 Section 2, your

response shall be answered fully in writing and shall be
signed and sworn by you.

c) 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.

d) 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. Since you admitted paragraph 1 of our complaint, how

did you meet or come to know the plaintiff?

2. How did you come to know of Ms. Rona Santos?

3. By “estranged relative”, what exact relationship status

are you referring to insofar as Ms. Arianne and Rona
Santos are concerned?

4. How come you know about the gambling and debt

problems of Ms. Rona Santos?

5. Who are the “several people” Ms. Rona Santos is indebted

to?

6. How come you know that Ms. Rona Santos left the
country?

7. When did Ms. Rona Santos leave the country and where
was she headed?

8. When did Ms. Arianne Santos become the President of

SISC?

9. What is the extent of Ms. Arianne Santos’ authority in the

SISC?

10. Did you, in the past, authorize Ms. Arianne Santos to

enter into any transaction on your behalf?

11. Are you aware of all the transactions entered into by

Ms. Arianne Santos in her capacity as President of SISC?

12. Of all such transactions, was Ms. Arianne Santos, in

her capacity as President of SISC, authorized by the
latter?

13. Did you know about the confirmation made by Ms.

Arianne Santos regarding the obligation of the former to
 the plaintiff? If not, how come did you not know about
this?

14. What was the intention of Ms. Arianne Santos in

confirming a debt of SISC?

15. What is the status or standing of Ms. Arianne Santos in

SISC insofar as her reputation and being trustworthiness
is concerned?

16. Is Ms. Arianne Santos authorized to delegate the

power to represent or bind or to enter into transactions in
behalf of SISC or any other similar power to others?

17. Did you know of the transactions between Ms. Arianne

Santos, in her capacity as President of SISC, and Ms.
Rona Santos with respect to the subject matter of the
complaint? If not, how come did you not know of the
transactions between them?

18. How come you are not aware of your existing

obligation to plaintiff when it was confirmed by your own
President?

19. How come plaintiff did not receive from you of any
document pertaining to “Annex 1” as mentioned on
paragraph 2 of your Answer (labeled as Reply)?

20. By “him” on the phrase “demand made to him by the

latter” on paragraph 3 of your Answer (labeled as Reply),
to whom are you referring to considering that both
Santoses are women and SISC is better addressed as
“it”?

21. By “obligation” in the phrase “settlement of the whole

obligation” mentioned in paragraph 3 of your Answer
(labeled as Reply), what existing obligation are you
referring to?

22. What is your protocol with respect to the receiving of

letters addressed to you or to any of your officers?

23. How reliable are the employees/officers of SISC who

receive these letters?

24. With respect to paragraph 4 of your Answer (labeled

as Reply), how come you did not receive any demand
 letter from the plaintiff when “several if not hundreds of
mail transactions from the Cebu City Central Post Office
addressed to you were duly accepted by your responsible
officers”?

25. In relation to the preceding question, do you mean to

say that your “responsible officers” did not at all bother to
read the contents of all the mails or letters you receive
from the said Post Office?

26. What is your definition of the word “responsible” as

used in the phrase “responsible officers” that you used?

27. How many times did it happen where some mails or

letters were misplaced or were not delivered to the
appropriate officer of your company after receiving it
from the Post Office?

28. What do you mean by “regardless of its contents” as

mentioned in paragraph 4 of your Answer (labeled as
Reply)?

29. What is meant by SEC and SGV on paragraph 6 of

your Answer (labeled as Reply)?

30. What specific company are you referring to on

paragraph 6?

31. How come the plaintiff did not receive from you of any
document pertaining to “Annex 2” as mentioned in
paragraph 6 of your Answer (labeled as Reply)?

32. On paragraph 8 of your Answer (labeled as Reply),

you mentioned on the last part “Jurisprudence provides
that” and then it ended there. Please enlighten us as to
the meaning of such phrase.

33. Why is it that Ms. Rona is an indispensable party as

you contended on paragraph 9 of your Answer (labeled as
Reply)?

34. We seem to have a confusion as to your prayer stating

that: “WHEREFORE, premises considered, it is most
respectfully prayed of this Honorable Court that complaint
be dismissed primarily on the grounds that WHEREFORE,
premises considered, it is respectfully prayed of this
Honorable Court to DISMISS and DENY the
 aforementioned Complaint for lack of merit in fact and in
law.” Please enlighten us.

Cebu City, Philippines, January 26, 2018.

ATTY. ARNOLD ARAN ABRIL

Counsel for the Defendant
CAMA (Carriedo, Abril, Macmac, Alvero) Law Firm
Phoenix Sun Business Park Tower 2, Maasim City
Attorney’s Roll No. 79023
IBP No. 984562 / June 30, 2018 / Cebu City
PTR No. 923723 / May 15, 2017 / Cebu City
MCLE No. 18-00046735 / October 17, 2018
arnoldabril@gmail.com
(032)-254-1712