The Supreme Court ruled that a party’s failure to respond to a Request for Admission can be deemed an implied admission of the facts stated in the request. This ruling highlights the importance of diligently addressing all requests during the discovery phase of litigation. It emphasizes the duty of parties to actively participate in clarifying factual matters to ensure a fair and efficient judicial process. The implications extend to all litigants, requiring them to be vigilant in responding to Requests for Admission to protect their interests and avoid adverse consequences due to implied admissions.

Silence as Consent: Unpacking Implied Admissions in Property Dispute

The case of Alexis C. Almendras v. South Davao Development Corporation, Inc. revolves around a property dispute where Alexis C. Almendras sought to annul a Deed of Sale (DOS) involving land he claimed to own. A crucial aspect of the case was Rolando Sanchez’s Request for Admission, which Almendras failed to respond to. The Supreme Court addressed whether this failure constituted an implied admission of the facts presented in the request, significantly impacting the outcome of the case and underscoring the importance of procedural compliance in legal proceedings. This analysis delves into the implications of this ruling.

The failure to respond to a Request for Admission can have severe consequences in Philippine litigation, as illustrated in this case. A Request for Admission is a procedural tool used during the discovery phase to clarify factual issues. When a party fails to properly respond, the matters contained in the request are deemed admitted. This principle is rooted in Section 26, Rule 23 of the Rules of Court, which states:

Effect of admission. – Any admission made by a party pursuant to such request is for the purpose of the pending action only and shall not constitute an admission by him for any other purpose, nor may the same be used against him in any other proceeding.

In this instance, Rolando Sanchez filed a Request for Admission asking Alexis Almendras to admit the genuineness of certain documents and the truth of specific facts related to the property sale. Almendras’s failure to respond led the trial court to conclude that he had impliedly admitted the matters specified in the request. This admission was critical because it included facts that undermined Almendras’s claim to the property. The court’s reliance on this implied admission ultimately led to the dismissal of Almendras’s complaint.

The Supreme Court upheld the trial court’s decision, emphasizing the importance of complying with procedural rules. The Court noted that Almendras did not provide a sworn statement specifically denying the matters in the Request for Admission or explaining why he could not admit or deny them. This failure, according to the Court, justified the trial court’s finding of an implied admission. The Court also addressed Almendras’s argument that he was not properly served with the Request for Admission, clarifying that the records showed otherwise.

The Supreme Court’s decision also highlighted the distinction between questions of law and questions of fact, which is crucial in determining the appropriate mode of appeal. The Court explained that a question of law arises when there is doubt about what the law is on a certain set of facts. Conversely, a question of fact arises when there is doubt about the truth or falsity of alleged facts. The Court cited Republic v. Malabanan, which provides a comprehensive explanation of this distinction:

x x x A question of law arises when there is doubt as to what the law is on a certain state of facts, while there is a question of fact when the doubt arises as to the truth or falsity of the alleged facts. For a question to be one of law, the same must not involve an examination of the probative value of the evidence presented by the litigants or any of them. The resolution of the issue must rest solely on what the law provides on the given set of circumstances. Once it is clear that the issue invites a review of the evidence presented, the question posed is one of fact. Thus, the test of whether a question is one of law or of fact is not the appellation given to such question by the party raising the same; rather, it is whether the appellate court can determine the issue raised without reviewing or evaluating the evidence, in which case, it is a question of law; otherwise it is a question of fact.

In Almendras’s case, the Supreme Court found that the issues raised involved questions of fact, particularly the alleged failure to serve the Request for Admission properly. Because these issues required an examination of the evidence, they were not appropriate for a petition for review on certiorari, which is limited to questions of law. The Court also pointed out that Almendras should have appealed to the Court of Appeals (CA) instead of directly to the Supreme Court, further underscoring the procedural missteps in his case. The correct approach, outlined in Five Star Marketing Company, Inc. v. Booc, details the modes of appeal:

The Court, in Murillo v. Consul, Suarez v. Villarama, Jr. and Velayo­Fong v. Velayo, had the occasion to clarify the three modes of appeal from decisions of the RTC, namely: a) ordinary appeal or appeal by writ of error, where judgment was rendered in a civil or criminal action by the RTC in the exercise of its original jurisdiction; b) petition for review, where judgment was rendered by the RTC in the exercise of its appellate jurisdiction; and c) petition for review to this Court. The first mode of appeal is governed by Rule 41, and is taken to the CA on questions of fact or mixed questions of fact and law. The second mode, covered by Rule 42, is brought to the CA on questions of fact, of law, or mixed questions of fact and law. The third mode, provided for by Rule 45, is elevated to this Court only on questions of law.

The failure to follow the proper appellate procedure was another critical factor in the Supreme Court’s decision to deny Almendras’s petition. This case serves as a reminder of the importance of understanding and adhering to the procedural rules governing litigation in the Philippines.

FAQs

What is a Request for Admission?	A Request for Admission is a discovery tool used in legal proceedings where one party asks the other to admit or deny the truth of specific facts or the genuineness of documents. It helps to streamline the trial process by establishing undisputed facts.
What happens if a party fails to respond to a Request for Admission?	Under the Rules of Court, if a party fails to respond to a Request for Admission within the prescribed period, the matters contained in the request are deemed admitted. This can significantly impact the outcome of the case.
What should a party do if they cannot admit or deny a Request for Admission?	If a party cannot either admit or deny a Request for Admission, they must provide a sworn statement explaining in detail the reasons why they cannot admit or deny the matters. The statement must be specific and justified.
What is the difference between a question of law and a question of fact?	A question of law involves uncertainty about what the law is on a particular set of facts, while a question of fact involves uncertainty about the truth or falsity of alleged facts. This distinction is crucial in determining the appropriate mode of appeal.
Why was the petitioner’s appeal denied in this case?	The petitioner’s appeal was denied because he raised questions of fact in a petition for review on certiorari, which is limited to questions of law. Additionally, he failed to appeal to the Court of Appeals before going to the Supreme Court.
What are the implications of this case for litigants in the Philippines?	This case underscores the importance of diligently responding to all requests and adhering to procedural rules in litigation. Failure to do so can result in adverse consequences, such as implied admissions and dismissal of the case.
What is a Motion for Summary Judgment?	A Motion for Summary Judgment is a request made by one party in a lawsuit, asking the court to rule in their favor without holding a trial. This motion is typically filed when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law.
What is the role of the Court of Appeals (CA) in the Philippine judicial system?	The Court of Appeals is an intermediate appellate court that reviews decisions of Regional Trial Courts. It handles appeals on questions of fact, questions of law, or mixed questions of fact and law, providing an essential layer of judicial review before cases reach the Supreme Court.

In conclusion, the Supreme Court’s decision underscores the critical importance of procedural compliance in Philippine litigation. Litigants must diligently respond to Requests for Admission to avoid implied admissions that can undermine their case. Furthermore, understanding the distinction between questions of law and questions of fact is essential for choosing the correct mode of appeal. Adhering to these principles ensures a fair and efficient judicial process.

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: ALEXIS C. ALMENDRAS v. SOUTH DAVAO DEVELOPMENT CORPORATION, INC., G.R. No. 198209, March 22, 2017