FACT CHART

Name of the Witness: Dan D. Lyon

Age: 32 years old
Sex: Male
Status: Single
Address: #97, Happy Homes, Magsaysay, Baguio City
Occupation: Building Administrator
Purpose of the Statement:
The statement of the above-named witness is relevant to
the case subject matter of the complaint for Unlawful detainer
to the effect that it establishes that fact:
a) That the witness was the legal representative of Janine
I. Aguilar, the lessee of Faye D. Lim relating to the land and
building located at #65 Engineer’s Hill, Baguio City owned by
the latter
b) That it is the Defendant who was outside of Baguio
City because of an urgent concern
c) That it is the witness who was present during the
examination of the leased premises done by the Lessor on
October 20, 2015.

The interview is hereto reproduced and submitted as

follows.

Preliminary Statement: Before we start, we would like

to inform you that this interview will be conducted in
relation to the case of Unlawful Detainer involving Faye D.
Lim and Janine I. Aguilar. Rest assured that everything
will be confidential and nothing stated herein shall be
used for other purposes without your prior approval.

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1. Q: Kindly state your name and personal
circumstances:
A: I am Dan D. Lyon, 32 years old, single, and a resident
of #97, Happy Homes, Magsaysay, Baguio City

2. Q: Do you know of a certain Janine I. Aguilar?

A: Yes, I know her.

3. Q: How did you know of this certain Janine I.

Aguilar?

A: I work for her as a building administrator for the

Engineer’s Hill Building.

4. Q: Where were you on October 20, 2015?

A: I was at the Engineers Hill Building overseeing the
business of Janine I. Aguilar when Faye D. Lim informed
me that she will inspect the premises.

5. Q: What did you do upon being notified that an

inspection shall be done in the premises?
A: I immediately called my boss, Janine I. Aguilar to
inform her that such inspection is about to be done in
the premises. However, I could not contact her so I
decided to allow Faye D. Lim to inspect the premises.

6. Q: What happened during the inspection?

A: It was found out that there were plumbing and
drainage issues. Also, the floors are wet and the waters
are starting to leak throughout the doors of the
Defendant’s room.

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7. Q: What happened next?
A: I requested Ms. Lim to make the necessary repairs in
the premises. However, she insisted that my boss shall
undertake the repairs in accordance with the contract.
Otherwise, she will be compelled to terminate the
contract.

8. Q: Is that request made in writing?

A: No. It was made orally during the course of inspection.

9. Q: What did you do thereafter?

A: I made a report in writing on what transpired during
that day and I submitted the same to Ms. Aguilar upon
her return the next day

10. Q: Upon informing Ms. Aguilar of the incident,

what did she tell you to do?
A: Ms. Aguilar insisted that she will not undertake the
repairs as she is convinced that it is the lessor who has
the obligation to be liable for the same. Thus, she
instructed me to talk with Ms. Lim again

11. Q: What did you do?

A: I then went to Ms. Lim to inform her about Ms.
Aguilar’s instructions.

12. Q: What happened then?

A: Ms. Lim asked me to make a request in writing for her
to decide upon the matter. So I made such request in
writing. However, Ms. Aguilar failed to sign the same as
she was out of time at that day. I then left the document

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 to her personal secretary so that the same will be signed
and communicated upon her return.

13. Q: Was she able to sign the document and submit

the same to Ms. Lim?
A: I am not sure. As far as I know, I gave it to her
assistant so that Ms. Aguilar can personally submit it to
Ms. Lim.

14. Thank you for helping us with our assignment.

Again, we repeat that everything you said will be
confidential and will be used primarily for the
purpose above-stated. Do you want to add more to
your statements?
A: No more.

Taking the above statements, made during the interview,

the following facts are therefore established:
1. That Dan D. Lyon is the authorized legal representative
of Janine I. Aguilar
2. That Janine I. Aguilar was not present during the
inspection done by Faye D. Lim
3. That the request for the repairs was done orally by Dan
D. Lyon during the course of the inspection.
4. That Ms. Aguilar insisted that Ms. Lim shall undertake
the repairs needed in the premises.
5. That Ms. Aguilar was not able to sign the written
request for she was again out of town.
6. That the written request was not communicated to Ms.
Lim due to the lack of Ms. Aguilar’s signature.

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