Facts:

• In Ayala Land Inc. v. Tagle, G.R. No. 153667, decided on August 11, 2005, the dispute involved the sale of real estate properties in Dasmariñas, Cavite City.
• ASB Realty Corporation (ASB) and E. M. Ramos and Sons, Inc. (EMRASON) filed Civil Case No. 931-94 before the Regional Trial Court (RTC) of Imus, Cavite City.
• They sought the nullification of a Contract to Sell Real Properties, cancellation of annotations on Transfer Certificates of Title, and damages against Ayala Land, Inc. (ALI) and others.
• On May 21, 1994, EMRASON, chaired by Emerito M. Ramos, Sr., entered into a Letter-Agreement with ASB for the conditional sale of 65% of its 372-hectare property for P400,000,000.00, payable in five installments.
• ASB later discovered that the Ramos children had entered into a Contract to Sell the same properties with ALI on May 18, 1994, which was annotated on the Transfer Certificates of Title.
• ASB filed a complaint on June 13, 1994. ALI responded with an Answer, Compulsory Counterclaim, and Cross-claim.
• ASB moved to take the deposition of Emerito Ramos, Sr., citing his advanced age. The deposition was taken on six occasions between November 22, 1994, and January 26, 1995.
• ALI objected to the deposition's propriety and admissibility, leading to a series of motions and orders.
• The trial court admitted the deposition, and ALI sought relief from the Court of Appeals, which denied their petition.
• After Emerito Ramos, Sr.'s death in 1999, ASB moved to introduce his deposition as evidence, which the trial court allowed.
• ALI's subsequent appeals were denied, leading to the present petition before the Supreme Court.

Issue:

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Ruling:

1. The Supreme Court ruled that the deposition of Emerito M. Ramos, Sr. is admissible under the rules.
2. The Supreme Court found that the petitioner, ALI, waived its right to cross-examine the deponent.
3. The Supreme Court held that the Court of Appeals did not comm...(Unlock)

Ratio:

• The Supreme Court explained that the deposition of Emerito M. Ramos, Sr. was taken in accordance with the rules, considering his advanced age as a valid ground.
• The deposition was conducted in the courtroom, with all parties and their counsels present, and was recorded by stenographers, tape recorders, and a video camera.
• The Court emphasized that the deposition discovery rules are to be accorded broad and liberal treatment to facilitate the discovery process and expedite litigation.
• The Court noted that the lack of the deponent's signature does not preclude the use of the deposition, as the prim...continue reading