Republic of the Philippines

7th Judicial Region

REGIONAL TRIAL COURT
BRANCH __
Cebu City

IMELDA I. CLARA
Plaintiff,
- versus - CIVIL CASE NO.
For: Collection for a sum
of Money with Damages

REY I. ABAD
Defendant
x- - - - - - - - - - - - - - - - - - - - - - x

WRITTEN INTERROGATORIES

TO: ATTY. JOHN MARTIN ( witness in the execution of promissory

note)
FROM: IMELDA I. CLARA, 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) 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 if any with the person who helped you in
the preparation of this document.
2. Do you know personally the plaintiff and defendant?
3. How did the three of you know each?
4. Are you aware of any unpaid obligation of defendant to
plaintiff?
5. How much therefore did the defendant borrowed from
plaintiff?
6. Do you remember defendant executing and preparing a
promissory note?
7. What was this promissory note for?
8. Where was this promissory made?
9. Was the promissory note prepared and executed in
your presence?
10. Was this promissory note signed by defendant?
11. Did you see him sign it personally in your
presence?
12. Where was it signed?
13. What proof do you have to verify that at the time
the promissory note was executed and prepared you
were in the defendant’s presence?
14. Did you bother to check the contents of this
promissory note?
15. What were its contents?

Respectfully submitted.

Cebu City, Philippines, March 22, 2019.

ATTY. JABAR A. SABDULLAH

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

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