REPUBLIC OF THE PHILIPPINES

Municipal Trial Court in Cities

Branch 1, Cebu City

JUAN ILOK,
Plaintiff,

-versus- CIVIL CASE NO. CEB-12345

BRAD ARMPIT,
Defendant. FOR: SUM OF MONEY
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ANSWER TO INTERROGATORIES

COMES NOW, defendant, through the undersigned counsel and unto this Honorable Court, most
respectfully submit this Answer to the Interrogatories propounded by the Complainant upon him, to wit:

1.What is your full legal name? Do you have any name that you are known for, list all of them.
State your permanent address and if you have any other residences other than your present.

ANSWER:Defendants full legal name is BRAD ARMPIT. Defendant is only known to the name of
Brad. Defendants permanent address is at 143 Gabuya Street, Pardo, Cebu City, Philippines.
Defendant has no other residences than the present.

2. What is your relation to the Complainant? How well do you know the complainants family
and for how long have you maintained the relationship. State the names of the family members
personally known to you including personal facts and attributes that distinguish ones identity.

ANSWER:The Complainant is Defendants neighbor.They have been good friends for a few years
now. Defendant knows that Complainant has a son named John Ilok.

3. Identify all persons or supplying information that shall be used in answering these
interrogatories.

ANSWER:Defendants counsel is answering these Interrogatories in behalf of the Defendant.

4. State the name, address, and contact numbers of each person with personal knowledge
regarding the facts and circumstances surrounding the happenings referred to in the complaint.

ANSWER: Juan Ilok, John Ilok, Pedro Siponon, Jose Kogmohon have personal knowledge
regarding the facts surrounding the happenings in the event. All are residents of Barangay
Pardo, Cebu City, Philippines. Juan Iloks contact number is 09919876543. John Iloks contact
number is 09432156798. Pedro Siponons contact number is 09123456789. Jose Kogmohons
contact number is 09987654321.
5. Explain in detail the circumstances on how you obtain the obligation to the complainant,
including the amount, the mode of payment and the manner of such payment.

ANSWER:Defendant went to the Complainants house on March 01, 2007, together with Pedro
Siponon and Jose Kogmohon, in order to borrow money worth ONE HUNDRED FIFTY THOUSAND
PESOS (P150,000) from Complainant. Defendant promised to pay said obligation on Juy 31,
2007, to which Complainant agreed. On July 20, 2007, Defendant went to Complainants house.
Complainant was not there at that time, so Defendanthanded to John Ilok, Complainants son,
FIFTY THOUSAND PESOS (P50,000) in cash as partial payment.On July 31, 2007, Defendant went
to Complainants house and handed to the latter ONE HUNDRED THOUSAND PESOS (P100,000)
in cash as full payment of the remaining balance.

6. State the manner of you compliance to such obligation and to the extent of the performance
of such including the exact circumstance on the occurrence of payment.

ANWER:On July 20, 2007, Defendant went to Complainants house. Complainant was not there
at that time, so Defendant handed to John Ilok, Complainants son, FIFTY THOUSAND PESOS
(P50,000) in cash as partial payment, instructing him to give the money to his father. On July 31,
2007, Defendant went to Complainants house and handed to the latter ONE HUNDRED
THOUSAND PESOS (P100,000) in cash as full payment of the remaining balance. Such payment
totally extinguished Defendants obligation to the Complainant.

7. State and describe in detail all evidence including documents, affidavit and/or statements not
submitted in the record in relation to the complaint.

ANSWER: Objection. This interrogatory is vague, overly broad and unduly burdensome and
seeks information protected by the attorney-client privilege.

8. State in detail any prior arrangement or agreement of settlement prior to the filing of this
case in court.

ANSWER: Defendant is willing to enter into an amicable settlement with Complainant. Both
have submitted the matter before the Barangay Conciliation prior to the filing of the complaint
in court. However, no agreement was reached.
 OATH

I do solemnly declare and affirm under the penalties of perjury that the foregoing Answers to
Interrogatories are true and correct to the best of my knowledge, information and belief.

BRAD ARMPIT

RESPECTFULLY SUBMITTED

KURIMAO, KURIMAO and ABLAO LAW OFFICE

Counsel for the Defendant
Suite 235 The Tower
Malate, Manila

By:

Atty. DESIREE E. KURIMAO

Roll No. 98765
IBP No, 12345/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila

Copy Furnished:

ATTY. PARK K. TILAOPAO

Counsel for the Plaintiff
Unit 1234 Apple One Building
Cebu City, Philippines