Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH 196
LAS PINAS

JOSH NAPIZA
Plaintiff,
- versus - CIVIL CASE NO. 7080
For:Unlawful Detainer,
Damages and
Attorney’s Fees

AJ CANICOSA
Defendant.
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WRITTEN INTERROGATORIES

TO: AJ CANICOSA, Defendant

FROM: JOSH NAPIZA, 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 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
expiration of the Contract of Lease?

Las Pinas City, Philippines, May 15, 2020.

ATTY. WILLIAM KYLE C.SANTOS

Counsel for the Plaintiff
Unit 1715, ABC Building, Las Pinas City
Roll No: 987654: 5/28/2019
IBP No. 456123:7/1/2019 - Las Pinas
PTR No. 741258:1/1/2020 - Las Pinas