In legal proceedings, requests for admission serve as a critical tool for streamlining the trial process. However, non-compliance and improper service can significantly impact the outcome of a case. The Supreme Court in Fortunata N. Duque v. Court of Appeals clarified the importance of properly serving requests for admission directly to the party involved, not just their counsel, to ensure valid and binding admissions. This ruling underscores the necessity for strict adherence to procedural rules to uphold fairness and due process in litigation.

Navigating Legal Admissions: When Silence Doesn’t Always Mean ‘Yes’

This case revolves around two complaints filed by Fortunata Duque and Marcosa Valenzuela against spouses Enrico and Edna Bonifacio. Duque and Valenzuela claimed the Bonifacios negotiated checks with them in exchange for cash, which later bounced. When the Bonifacios failed to respond to a Request for Admission, the trial court deemed it an implied admission of their liability. The Court of Appeals (CA), however, reversed this decision, stating that the requests were improperly served and pertained to matters already denied in the spouses’ answers. The central legal question is whether the Bonifacios’ silence constituted an admission, and if the service of the request was valid.

The Supreme Court, in analyzing the case, focused on the proper application of Rule 26 of the Revised Rules of Court, which governs requests for admission. This rule allows a party to request another party to admit the genuineness of relevant documents or the truth of relevant facts. The goal is to expedite trials by reducing the need to prove undisputed matters. However, the Court emphasized that this tool should not be used to create redundancy or delay proceedings. Here the Supreme Court citing Po vs. Court of Appeals, provides clarity by stating that:

“A party should not be compelled to admit matters of fact already admitted by his pleading and concerning which there is no issue (Sherr vs. East, 71 A2d, 752, Terry 260, cited in 27 C.J.S. 91), nor should he be required to make a second denial of those already denied in his answer to the complaint. A request for admission is not intended to merely reproduce or reiterate the allegations of the requesting party’s pleading but should set forth relevant evidentiary matters of fact, or documents described in and exhibited with the request, whose purpose is to establish said party’s cause of action or defense. Unless it serves that purpose, it is, as correctly observed by the Court of Appeals, ‘pointless, useless’ and ‘a mere redundancy.’”

In the case at hand, the petitioners sought admission on three key points: the negotiation of checks, the execution of promissory notes, and the receipt of demand letters. The Court found that the request regarding the checks was redundant, as the respondents had already denied personally negotiating them in their answer. Demanding a second denial on this point was deemed superfluous and against the spirit of Rule 26.

Regarding the promissory notes, the Court agreed with the CA that the request was defective. The petitioners failed to attach copies of the notes or prove that the respondents had previously been furnished with copies. This omission violated Section 1 of Rule 26, which requires that relevant documents be exhibited with the request unless already provided. The Court emphasized the importance of adhering to this procedural requirement to ensure fairness and prevent surprise.

Similarly, the Court found the request regarding the demand letters improper. The respondents had already denied receiving such demands in their answer, making a further admission unnecessary. The Court reiterated that requests for admission should not be used to reiterate allegations already addressed in the pleadings. To reiterate the Supreme Court in Po vs. Court of Appeals states:

“A request for admission is not intended to merely reproduce or reiterate the allegations of the requesting party’s pleading but should set forth relevant evidentiary matters of fact, or documents described in and exhibited with the request, whose purpose is to establish said party’s cause of action or defense. Unless it serves that purpose, it is, as correctly observed by the Court of Appeals, ‘pointless, useless’ and ‘a mere redundancy.’”

The Court also addressed the critical issue of service. The petitioners argued that serving the request on the respondents’ counsel was sufficient. However, the Court disagreed, citing the Briboneria case, which held that when the law expressly requires service on a specific person, service on their counsel is insufficient. This principle underscores the importance of direct notice to the party involved, especially in matters as crucial as requests for admission.

“The general rule as provided for under Section 2 of Rule 27 (now Section 2, Rule 13) of the Rules of Court is that all notices must be served upon counsel and not upon the party. This is so because the attorney of a party is the agent of the party and is the one responsible for the conduct of the case in all its procedural aspects; hence, notice to counsel is notice to party. The purpose of the rule is obviously to maintain a uniform procedure calculated to place in competent hands the orderly prosecution of a party’s case (Chainani vs. Judge Tancinco, G.R. No. L-4782, Feb. 29, 1952; Capili v. Badelles, G.R. No. L-17786, Sept. 29, 1962). However, the general rule cannot apply where the law expressly provides that notice must be served upon a definite person. In such cases, service must be made directly upon the person mentioned in the law and upon no other in order that the notice be valid.”

Since the requests for admission were not validly served, the respondents could not be deemed to have admitted the truth of the matters requested. This lack of valid admission undermined the legal basis for the summary judgment rendered by the trial court. The Supreme Court, therefore, affirmed the CA’s decision to remand the case for trial on the merits, ensuring that the issues would be properly adjudicated with due consideration of the evidence and arguments presented.

The ruling emphasizes the importance of strict compliance with procedural rules, particularly regarding requests for admission. Attorneys must ensure that requests are properly served on the parties involved and that they pertain to matters not already addressed in the pleadings. Failure to do so can result in the invalidation of admissions and the need for a full trial. Furthermore, the decision underscores the need for parties to actively participate in the litigation process, as their silence can have significant legal consequences.

FAQs

What was the key issue in this case?	The key issue was whether the failure of the respondents to respond to a request for admission constituted an implied admission under the Rules of Court, and whether the service of the request was valid.
What is a request for admission?	A request for admission is a legal tool used to obtain admissions from the opposing party regarding the genuineness of relevant documents or the truth of relevant facts, aiming to expedite the trial process.
Why did the Court of Appeals reverse the trial court’s decision?	The Court of Appeals reversed the trial court because the requests for admission were improperly served and pertained to matters already denied in the respondents’ answers.
On whom should a request for admission be served?	A request for admission should be served directly on the party involved, not just their counsel, to ensure valid and binding admissions.
What happens if a party fails to respond to a request for admission?	If a party fails to respond to a request for admission, the matters in the request may be deemed admitted, but only if the service of the request was proper and the matters are not already denied in the pleadings.
What is the purpose of Rule 26 of the Revised Rules of Court?	Rule 26 seeks to obtain admissions from the adverse party regarding the genuineness of relevant documents or relevant matters of fact to facilitate an amicable settlement of the case or expedite the trial.
Why was the request regarding the promissory notes deemed defective?	The request was deemed defective because the petitioners failed to attach copies of the notes to the request or prove that the respondents had previously been furnished with copies.
Can a request for admission be used to reiterate allegations already addressed in the pleadings?	No, requests for admission should not be used to reiterate allegations already addressed in the pleadings; they should set forth relevant evidentiary matters of fact.
What was the significance of the Briboneria case in this ruling?	The Briboneria case established that when the law expressly requires service on a specific person, service on their counsel is insufficient, reinforcing the need for direct notice to the party involved.

This case underscores the critical importance of adhering to procedural rules in litigation. Attorneys must ensure that requests for admission are properly served and that they pertain to relevant and previously unaddressed matters. Failure to do so can undermine the legal basis for judgments and necessitate a full trial on the merits. This ruling serves as a reminder of the need for diligent and informed legal practice, ensuring that all parties receive due process and a fair hearing.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: FORTUNATA N. DUQUE, VS. COURT OF APPEALS, G.R. No. 125383, July 02, 2002