Republic of the Philippines
Sixth Judicial Region
MUNICIPAL TRIAL COURT IN CITIES
BRANCH 10
Iloilo City
Ground Floor, Iloilo City Hall of Justice
Bonifacio Drive, Iloilo City
PEOPLE OF THE PHILIPPINES
- versus - Criminal Case No. R39-23
For: Falsification of Public
Document (Article 172 in
relation to Article 171
paragraph 4, all of the Revised
Penal Code as amended by
Section 26 of R.A. 10951
LANNY GALENO DAZA
Accused.
x-----------------------------------------x
DEPOSITION UPON WRITTEN INTERROGATORIES
(With Leave of Court)
DEPOSITION UPON WRITTEN INTERROGATORIES OF EMMA DAZA DATO-ON
(Through the Philippine Consular Office, Canada)
TO: THE HONORABLE PHILIPPINE CONSULAR OFFICER Philippine Consular Office
[Address], Canada
GREETINGS:
Pursuant to the Rules of Court, particularly Rule 23, Sections 11 and 12, and with
leave of court, the Prosecution, through the undersigned private prosecutor under
the direct control and supervision of the public prosecutor, respectfully propounds
the following written interrogatories to private complainant EMMA DAZA DATO-ON,
also known as MARIA EMMA DAZA DATO-ON, to be answered under oath before the
Philippine Consular Officer in Canada, within the period fixed by the Honorable
Court:
I. Identity and Jurisdiction
1. Please state your full name, age, civil status, citizenship, and current address.
2. Are you the same person as the private complainant in this case for
falsification of public document against Lanny Galeno Daza? Please state the
basis of your knowledge.
3. Do you personally know the accused, Lanny Galeno Daza? If yes, please state
how you are related to him.
4. Do you confirm that the person appearing in this trial as the accused is the
same person named in the Information as Lanny Galeno Daza?
5. Do you acknowledge the jurisdiction of the Honorable Court over the subject
matter of this case and over the person of the accused?
6. Did you authorize Atty. Mary Louise S. Villegas to act as your attorney-in-fact
in connection with the settlement of the estate and the filing of this
complaint? If so, please describe the circumstances and attach a copy of the
Special Power of Attorney.
7. Please narrate the circumstances that led to the filing of the complaint for
falsification and use of falsified documents against the Respondent.
II. Family and Succession Facts
8. Do you confirm that Nicolas Daza is the original registered owner of Lot 3452
covered by Original Certificate of Title No. O-3843? Please state the basis of
your knowledge.
9. Are you one of the heirs of the late registered owners of Lot 3452 located in
Barrio San Matias, Municipality of Dingle, Iloilo? Please explain.
10. Do you confirm that Nicolas Daza was married to Florentina Ayupan? Please
state the basis of your knowledge.
11. Do you confirm that Nicolas Daza and Florentina Ayupan had two children,
namely, Gabriel Daza and Angela Daza? Please state the basis of your
knowledge.
12. Do you confirm that Angela Daza died without heirs? If yes, please state the
basis of your knowledge.
13. Do you confirm that Gabriel Daza, married to Gregoria Mesisado, had four
children, namely: Elpidio Daza, Hilario Daza, yourself (Emma Daza-Dato-on),
and Salvacion Daza? Please state the basis of your knowledge.
14. Please state the number of children of each of the following: Elpidio Daza,
Hilario Daza, yourself, and Salvacion Daza.
15. Do you confirm that you are one of the four children of Gabriel Daza, and thus
a grandchild of Nicolas Daza?
16. Do you confirm that the accused’s father is Hilario Daza, your brother? Please
state the basis of your knowledge.
III. Heirship and Adjudication
17. Do you confirm that the accused, Lanny Galeno Daza, is not the sole heir of
Nicolas Daza? Please explain your answer.
18. Do you confirm that the accused is not a direct child of Nicolas Daza, but
rather a great-grandchild? Please explain your answer.
19. Do you confirm that the accused executed a Notarized Deed of Adjudication
dated December 30, 2021, claiming to be the sole heir of Nicolas Daza? If yes,
how did you obtain a copy of said document?
20. Are you in possession of the original or a certified true copy of the said Deed
of Adjudication? If yes, please describe the document and how you obtained
it.
21. Do you confirm that the accused used the Deed of Adjudication dated
December 30, 2021, to cause the transfer of Original Certificate of Title No. O-
3843 from Nicolas Daza to himself? Please state the basis of your knowledge.
22. Do you confirm that the accused was issued Transfer Certificate of Title No.
090-2022009619 as a result of the said transfer? Please state the basis of
your knowledge.
IV. Documents and Correspondence
23. Do you confirm the existence, due execution, and truthfulness of the
following documents? For each, please state if you have the original, a copy,
or have seen the document, and describe its contents to the best of your
knowledge:
1. a. Special Power of Attorney executed by you in favor of Atty. Mary
Louise S. Villegas and/or Atty. Stewart Paul T. Torre dated March 26,
2024;
2. b. Printed copy of the Family Tree of Nicolas Daza and Florentina
Ayupan;
3. c. Letter dated February 8, 2022, drafted and sent by your Attorney-in-
Fact, Atty. Mary Louise S. Villegas, addressed to the accused;
4. d. Letter dated August 11, 2022, regarding your intent to sell your
cumulative undivided 2/3 rights/shares over Lot 3452;
5. e. Letter dated September 13, 2022, with demands for amicable
settlement, division of property, and payment of shares;
6. f. Certified true copy of the Deed of Adjudication dated December 30,
2021;
7. g. Your passport;
8. h. Passport of Salvacion Daza;
9. i. Senior Citizen ID, Driver’s License, and SSS ID of Elpidio Daza; j. The
accused’s Rejoinder to Complainant’s Reply Affidavit (Statement #9,
page 2); k. Certified true copy of the Deed of Adjudication attached to
the accused’s Rejoinder; l. Certified true copy of Transfer Certificate of
Title No. 090-2022009619; m. Comparative Table showing the
signatures of the children of Nicolas Daza.
V. Additional Matters
24. Are you aware of any other documents, public or private, that pertain to the
ownership, adjudication, or transfer of Lot 3452? If yes, please identify and
describe them.
25. Do you have any other information or evidence to support your claim that the
accused falsified the Deed of Adjudication or misrepresented himself as the
sole heir of Nicolas Daza?
VI. Verification
26. Do you swear that all your answers to the foregoing interrogatories are true
and correct to the best of your knowledge, information, and belief?
IN WITNESS WHEREOF, I have hereunto set my hand this ___ day of ____________, 2025.
Respectfully submitted:
ATTY. STEWART PAUL T. TORRE Roll of Attorneys No.: 67265 IBP No.: 525916; PTR
No.: 9697909 MCLE Compliance No. VIII-0035691 09478929387 / (033) 325-0148
Email Address: stewartpaultorre@[Link] Private Prosecutor Ground Floor TSKI
Building National Highway, Brgy. Maliao, Pavia, Iloilo
Copy furnished:
PROS. CHRISTOPHER L. DEQUILLA ILOILO CITY PROSECUTION OFFICE 2nd Floor,
Chief Justice Ramon Avanceña Hall of Justice Bonifacio Drive, Iloilo City
[Link]@[Link]
