When is a Request for Admission Improper? Understanding Rule 26 and Its Limits

G.R. No. 117574, January 02, 1997

Imagine a scenario: you’ve already laid out your claims in court, and the opposing party sends you a ‘Request for Admission,’ essentially asking you to confirm or deny the very things you’ve already stated. Frustrating, right? This case, Concrete Aggregates Corporation v. Court of Appeals, delves into the proper use of Requests for Admission under Rule 26 of the Rules of Court, and what happens when a party fails to respond to such a request under oath. It highlights that a Request for Admission is improper when it merely reiterates matters already stated in the pleadings and emphasizes the importance of sworn statements in legal proceedings.

The Purpose and Scope of Requests for Admission

Rule 26 of the Rules of Court governs the use of Requests for Admission as a mode of discovery. The primary goal is to streamline trials by enabling parties to ascertain facts that are not in dispute. By compelling a party to admit or deny specific facts, the scope of the trial can be narrowed, saving time and resources. However, the rule is not without its limitations. The Supreme Court has consistently held that Requests for Admission should not be used to simply reiterate matters already raised in the pleadings. To understand this, let’s look at the specific wording from the Rules of Court:

Sec. 1. Request for admission. – At any time after issues have been joined, a party may serve upon any other party a written request for the admission by the latter of the genuineness of any relevant documents described in and exhibited with the request or of the truth of any relevant matters of fact set forth in the request.

This means that requests must go beyond what’s already known and seek to establish new facts or validate existing documents. If a party has already addressed an issue in their pleadings, a request for admission on the same issue is considered redundant and improper.

For example, imagine a car accident case. The plaintiff claims the defendant ran a red light. The defendant denies this in their answer. Sending a Request for Admission asking the defendant to admit they ran a red light would be improper because it simply restates the core issue already in dispute.

The Concrete Aggregates Case: A Story of Redundant Requests

Concrete Aggregates Corporation (CAC) hired 101 Security and Detective Services, owned by Vivien Soriguez, to provide security for its Cebu plant. After a theft occurred, CAC terminated the security services, alleging dissatisfaction. Soriguez sued CAC for unpaid fees and damages, claiming unlawful termination. CAC refused to pay, arguing that Soriguez was responsible for the losses from the theft and that this could be legally offset against the unpaid fees.

Here’s where the procedural twist comes in:

• Soriguez filed a complaint for unpaid fees and damages.
• CAC answered, denying liability and claiming set-off due to the theft.
• CAC then sent Soriguez a Request for Admission, asking her to admit responsibility for the theft.
• Soriguez responded with a Manifestation and Reply, denying responsibility, but it was not under oath.
• CAC moved for Summary Judgment, arguing that Soriguez’s failure to respond under oath constituted an admission.

The trial court denied CAC’s motion, and the Court of Appeals affirmed. The Supreme Court also denied CAC’s petition, holding that the Request for Admission was improper because it merely reiterated CAC’s claims in its Answer. The Court emphasized that a Request for Admission should seek to establish new facts, not simply rehash existing allegations. As the Court stated:

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.

Furthermore, the Court also noted that even if a response was required, Soriguez had substantially complied by specifically denying the allegations in her Manifestation and Reply. The lack of an oath was deemed a formal, not substantive, defect.

“While we commend petitioner’s zeal in promoting faithful adherence to the rules of procedure we cannot ignore the well-entrenched doctrine that all pleadings should be liberally construed as to do substantial justice.”

Practical Implications and Key Lessons

This case provides valuable guidance on the proper use of Requests for Admission and the consequences of non-compliance. The key takeaway is that Requests for Admission should not be used as a lazy way to confirm existing allegations. They should be targeted at establishing new, relevant facts that can help expedite the trial process.

Key Lessons:

• Requests for Admission should seek new information: Don’t use them to simply rehash what’s already in the pleadings.
• Substance over form: Courts may overlook minor procedural defects if the intent to deny is clear.
• Genuine issues of fact preclude summary judgment: If there are real disputes about the facts, the case must go to trial.

Frequently Asked Questions

Q: What is a Request for Admission?

A: It’s a written request served on the opposing party, asking them to admit or deny the truth of certain facts or the genuineness of documents.

Q: When is it appropriate to use a Request for Admission?

A: When you need to establish facts that are not already in dispute and can help narrow the issues for trial.

Q: What happens if I don’t respond to a Request for Admission?

A: Under Rule 26, the matters in the request are deemed admitted if you don’t respond within the prescribed timeframe.

Q: Does my response to a Request for Admission need to be under oath?

A: Yes, generally, your response must be under oath to be valid. However, courts may relax this requirement in certain circumstances.

Q: Can I be compelled to admit facts that I’ve already denied in my pleadings?

A: No, Requests for Admission should not be used to force you to re-deny facts you’ve already contested.

Q: What is a summary judgment?

A: It’s a judgment granted by the court without a full trial if there are no genuine issues of material fact in dispute.

Q: What happens if I don’t respond under oath to a request for admission?

A: Generally the matters in the request are deemed admitted. However, if it is clear that the party intended to deny the matters, the court may consider the lack of oath as a formal defect and allow the response.

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