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RULE 25.

WRITTEN INTERROGATORIES

Section 1. Interrogatories to parties; service thereof. –


Under the same conditions specified in section 1 of Rule 23,
any party desiring to elicit material and relevant facts from any
adverse parties shall file and serve upon the latter written
interrogatories to be answered by the party served or, fi the
party served is a public or private corporation or a partnership
or association, by any officer thereof competent to testify in its
behalf.

Rule 23, Section 1. Depositions pending action, when may be taken. — By leave of
court after jurisdiction has been obtained over any defendant or over property which is
the subject of the action, or without such leave after an answer has been served, the
testimony of any person, whether a party or not, may be taken, at the instance of any
party, by deposition upon oral examination or written interrogatories. The attendance
of witnesses may be compelled by the use of a subpoena as provided in Rule 21.
Depositions shall be taken only in accordance with these Rules. The deposition of a
person confined in prison may be taken only by leave of court on such terms as the
court prescribes. (1a, R24)

When to file written interrogatories?

The time within which to file and serve written interrogatories is


explicitly fixed by the rules, that is, in civil cases before responsive answer
is filed with leave of court or without leave of court after the filing of
responsive answer; and in criminal cases before the setting of the
arraignment and pre-trial conference. The admissions made in the verified
answer to the written interrogatories may already be considered during
the pre-trial conference and would definitely aid the parties for purposes
of a plea-bargaining.