The Supreme Court ruled that parties are not required to respond to requests for admission that merely reiterate allegations already made in their pleadings, especially when those allegations have been previously denied. This decision clarifies the scope and purpose of Rule 26 of the Rules of Court, emphasizing that requests for admission should seek to clarify facts, not simply repeat existing claims. The Court also clarified that even if a response is needed, a formal defect like the lack of an oath can be excused if there’s substantial compliance with the rule, and that requests for admission cannot be used for questions of law or opinion.

DBP’s Defense: When Redundant Questions Don’t Need Answers

This case arose from a dispute between Development Bank of the Philippines (DBP) and Rosalinda Canadalla-Go over the redemption of foreclosed properties. Irene Canadalla, Rosalinda’s mother, had obtained loans from DBP secured by real estate mortgages. After failing to meet her obligations, DBP foreclosed the mortgages and acquired the properties at public auction. Rosalinda, as assignee of her mother’s right to redeem, attempted to redeem the properties, but disagreements arose over the redemption price. Subsequently, Rosalinda filed a Supplemental Complaint, and during the proceedings, requested DBP to admit matters already stated in her complaint. The central legal question was whether DBP was compelled to respond to this request for admission under Rule 26, particularly when the matters reiterated allegations already present and specifically denied in the pleadings.

The Supreme Court addressed whether DBP should be considered as having impliedly admitted the matters in Go’s Request for Admission. The Court referred to Sections 1 and 2 of Rule 26 of the Rules of Court before the 1997 amendments, which detail the request for admission process and the consequences of failing to properly respond. The Court then cited Po v. Court of Appeals, stating that a party should not be compelled to admit facts already admitted in their pleading and should not be forced to make a second denial of what was already denied in their answer to the complaint.

SECTION 1.  Request for admission. – At any time after issues have been joined, a party may file and 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 matter of fact set forth in the request. Copies of the documents shall be delivered with the request unless copies have already been furnished.

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 the matters of which an admission is requested or setting forth in detail the reasons why he cannot truthfully either admit or deny those matters.

Objections on the ground of irrelevancy or impropriety of the matter requested shall be promptly submitted to the court for resolution.

Building on this principle, the Court cited Concrete Aggregates Co. v. Court of Appeals, which held that a response to a request is not required if the factual allegations in the complaint are the same as those in the request for admission and have already been addressed in the answer. The Court stated that Rule 26 is a mode of discovery intended to clarify and shed light on the truth or falsity of allegations in the pleadings, not to reiterate what has already been alleged.

A request for admission that merely reiterates the allegations in an earlier pleading is inappropriate under Rule 26 of the Rules of Court, which, as a mode of discovery, contemplates of interrogatories that would clarify and tend to shed light on the truth or falsity of the allegations in the pleading. Rule 26 does not refer to a mere reiteration of what has already been alleged in the pleadings.

The Court then reasoned that since DBP’s Answer already controverted the averments in Go’s complaint and those recopied in the request for admission, DBP was not obligated to file a Comment on Go’s Request for Admission. Even assuming a reply was needed, DBP had filed its Comment either admitting or specifically denying the matters sought to be admitted, stating the reasons. The Court excused the lack of an oath in the Comment as a formal defect, noting that pleadings should be liberally construed to do substantial justice, and that the filing of such Comment substantially complied with Rule 26.

Moreover, the Court pointed out that DBP had submitted a Manifestation with an affidavit incorporating specific denials of Go’s factual allegations, filed immediately after the Comment and before the RTC’s order. This filing amounted to substantial compliance with Rule 26. Some matters sought to be admitted in the Request for Admission pertained to matters of law or opinions, which are not proper subjects for admission under Section 1 of Rule 26, which states that parties can request admission of the genuineness of relevant documents or the truth of relevant matters of fact. It is not meant for admission of matters of law, conclusions, or opinions.

The Court also found that the Court of Appeals erred in ruling that DBP failed to timely raise its objections to the impropriety of the matters requested for admission. DBP’s objection to the impropriety of some of the matters requested was promptly made as early as the filing of its comment on the request for admission. Furthermore, DBP’s counsel manifested this in open court during the 20 May 1997 hearing. In conclusion, the Court emphasized that the rule on admission as a mode of discovery is intended to expedite trial and relieve parties of the costs of proving facts which will not be disputed on trial and the truth of which can be ascertained by reasonable inquiry.

FAQs

What was the key issue in this case?	The key issue was whether a party is required to respond to a request for admission that merely reiterates allegations already made in their pleadings, especially when those allegations have been previously denied.
What is a request for admission under Rule 26 of the Rules of Court?	A request for admission is a written request served by one party to another, asking them to admit the genuineness of relevant documents or the truth of relevant facts. It is a discovery tool intended to expedite trials by clarifying undisputed facts.
When is a party not required to respond to a request for admission?	A party is not required to respond if the request merely reiterates allegations already made in the complaint and those allegations have been specifically denied or otherwise dealt with in the answer.
What happens if a party fails to respond to a request for admission?	If a party fails to respond properly to a request for admission, the matters for which admission was requested may be deemed impliedly admitted.
Can a request for admission be used for questions of law or opinion?	No, a request for admission is intended for matters of fact, not matters of law, conclusions, or opinions.
What constitutes substantial compliance with Rule 26?	Substantial compliance may involve filing a comment that addresses the matters sought to be admitted, even if the comment is not under oath, provided that the party also provides specific denials of the factual allegations in an affidavit.
What is the purpose of the rule on admission as a mode of discovery?	The rule is intended to expedite trials and relieve parties of the costs of proving facts that will not be disputed at trial, where the truth can be ascertained by reasonable inquiry.
What did the Supreme Court rule in this case?	The Supreme Court ruled that DBP was not required to respond to the Request for Admission because it merely reiterated allegations from the complaint, which DBP had already denied in its Answer. The Court reversed the Court of Appeals’ decision.

This Supreme Court decision underscores the importance of using requests for admission judiciously and appropriately. By clarifying that parties need not respond to redundant requests, the Court promotes efficiency in legal proceedings and prevents the misuse of discovery rules to harass or delay litigation. This ruling provides a practical guide for lawyers and litigants on the proper scope and application of Rule 26 of the Rules of Court.

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: DEVELOPMENT BANK OF THE PHILIPPINES vs. HONORABLE COURT OF APPEALS AND ROSALINDA CANADALLA-GO, G.R. NO. 153034, September 20, 2005