The Supreme Court clarified that a lawyer can answer a Request for Admission on behalf of their client. This means clients don’t always have to personally respond to these requests during legal proceedings. The Court emphasized the importance of efficient legal processes, preventing unnecessary delays. This ruling simplifies legal procedures, reduces burdens on clients, and ensures lawyers can fully represent their clients’ interests while maintaining the integrity and swiftness of legal proceedings.

Can Your Lawyer Answer for You? Understanding Requests for Admission

The case of Rey Lañada vs. Court of Appeals and Sps. Rogelio and Eliza Hemedez, and Nestle Philippines, Inc. and Francis Santos vs. Court of Appeals and Sps. Rogelio and Eliza Hemedez, stemmed from a tragic vehicular accident during a strike at Nestle Philippines. The accident resulted in Dr. Vied Vemir Garcia Hemedez’s death, leading his parents, the Hemedez spouses, to file a civil case for damages against multiple parties, including Nestle, its employee Francis Santos, truck owner Jesus Alimagno, driver Pacifico Galasao, and PC/Capt. Rey Lañada. A key procedural issue arose when the Hemedez spouses sought admissions from the defendants regarding the facts of the case. The defendants’ counsel answered the request for admission on their behalf. The Hemedez spouses challenged this, arguing that the parties themselves, not their lawyers, should personally answer the request.

The core legal question before the Supreme Court was whether a counsel could answer a Request for Admission under Rule 26 of the Rules of Court on behalf of their client. Rule 26, Section 2 states:

SEC. 2. Implied admission. – Each of the matters of which an admission is requested shall be deemed admitted unless, within a period designated in the request, which shall not be less than ten (10) days after service thereof, or within such further time as the court may allow on motion and notice, the party to whom the request is directed serves upon the party requesting the admission a sworn statement either denying specifically or setting forth in detail the reasons why he cannot truthfully either admit or deny those matters.

The Hemedez spouses interpreted “the party to whom the request is directed” to mean that only the individual party could respond, not their counsel. This interpretation raised concerns about the role and authority of legal representation in the admission process. To address this, the Supreme Court looked into existing legal principles.

The Supreme Court emphasized the principle of agency, as enshrined in the Civil Code. It also cited Section 23 of Rule 138 of the Rules of Court, which states that “(a)ttorneys have authority to bind their clients in any case by any agreement in relation thereto made in writing, and in taking appeals, and in all matters of ordinary judicial procedure x x x .” Building on this, the Court also referred to PSCFC Financial Corporation v. Court of Appeals, where it had previously addressed the issue of counsel responding to requests for admission. In that case, the Court held that a restrictive interpretation of Rule 26 would negate agency principles and the authority of attorneys. This earlier ruling established a precedent for allowing counsel to respond on behalf of their clients, provided they are authorized to do so.

The Court held that “when Rule 26 states that a party shall respond to the request for admission, it should not be restrictively construed to mean that a party may not engage the services of counsel to make the response in his behalf.” The Court reasoned that a strict interpretation would undermine the principles of agency and the authority of attorneys to act on behalf of their clients. Unless specifically required, such as in instances demanding a special power of attorney, counsel are presumed authorized to represent their clients. Here is a comparison of the two viewpoints:

Argument for Individual Response	Argument for Counsel Response
Strict interpretation of Rule 26 requiring personal response	Principles of agency and attorney authority
Potential for more accurate and direct admissions	Efficiency and legal expertise in responding

The Supreme Court further noted that the matters in the request for admission were substantially the same as those already addressed in the defendants’ answers to the complaint. Therefore, requiring a second, identical response would be redundant and delay the proceedings. This echoed the Court’s stance in Po v. Court of Appeals, which discouraged compelling a party to admit facts already admitted in their pleadings. The Court emphasized the need to prevent redundancy and expedite legal proceedings.

FAQs

What was the main issue in this case?	The main issue was whether a lawyer can answer a Request for Admission on behalf of their client, or if the client must answer personally.
What is a Request for Admission?	A Request for Admission is a legal procedure where one party asks the other to admit the truth of certain facts or the genuineness of documents relevant to the case.
What does the ruling mean for clients?	The ruling means that clients do not always have to personally answer Requests for Admission; their lawyers can do so on their behalf.
Why did the Court allow lawyers to respond?	The Court allowed lawyers to respond to uphold the principles of agency and the attorney’s authority to represent their clients effectively.
What happens if a party doesn’t respond to a Request for Admission?	If a party fails to respond within the specified time, the matters in the request are deemed admitted.
Is a lawyer always authorized to answer for their client?	Yes, unless there’s a specific requirement for a special power of attorney or the client objects to the lawyer’s response.
What if the matters in the request are already in the pleadings?	The Court discourages requiring a second admission of facts already admitted or denied in the pleadings to avoid redundancy and delays.
How does this ruling affect legal proceedings?	This ruling streamlines legal proceedings by preventing unnecessary delays and ensuring efficient use of legal resources.

In conclusion, the Supreme Court clarified that a lawyer’s response to a Request for Admission on behalf of their client is valid, reinforcing the attorney’s role in representing their client’s interests effectively and promoting the efficiency of legal proceedings. This decision underscores the Court’s commitment to balancing procedural rules with practical considerations in the pursuit of justice.

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: Rey Lañada vs. Court of Appeals and Sps., G.R. No. 102390, February 1, 2002