Case Digest (G.R. No. 125383)
Facts:
Fortunata N. Duque and Marcosa D. Valenzuela v. Court of Appeals and Spouses Enrico Bonifacio and Dra. Edna Bonifacio, G.R. No. 125383, July 02, 2002, Supreme Court First Division, Austria‑Martinez, J., writing for the Court.Petitioners Duque and Valenzuela separately sued respondents Spouses Enrico and Edna Bonifacio in the Regional Trial Court (RTC) of Valenzuela alleging that the spouses negotiated certain checks in exchange for cash (P270,000 for Duque; P432,000 for Valenzuela), that the spouses claimed to be holders in due course and that the checks were funded, and that the checks were later dishonored despite plaintiffs' notices and demands. Each complaint attached the checks and alleged demand letters. Respondents denied negotiating the checks, denied representing themselves as holders in due course, disputed the amounts and denied refusing to honor or replace the checks, claiming they arranged settlements only for checks actually issued by them.
After pre‑trial, petitioners served (filed) Requests for Admission on November 22, 1988 asking respondents to admit three matters: (1) they negotiated the checks annexed to the complaints; (2) Edna Bonifacio executed promissory notes dated November 23, 1987 acknowledging indebtedness in the stated amounts; and (3) plaintiffs’ demand letters dated November 28, 1987 were received by defendants on December 5, 1987. Respondents did not file sworn denials to the requests.
On December 27, 1988 the RTC, citing Sections 1 and 2, Rule 26, deemed the matters admitted and set the cases submitted. On February 1, 1989 the RTC rendered judgment in favor of the plaintiffs, ordering the spouses to pay P270,000 and P432,000 respectively, with interest. Respondents appealed to the Court of Appeals.
On March 13, 1996 the Court of Appeals vacated and set aside the RTC judgment and remanded the cases for trial on the merits, holding that (a) several matters in the Requests for Admission merely repeated allegations already denied in the Answers and were thus redundant; and (b) the Requests were filed in court and not properly served on the appellants as required by Section 1, Rule 26, citing this Court’s decision in Briboneria v. Court of Appeals. Petitioners’ motion for reconsideration was denied by the CA in...(Pro-only)
Issues:
- Did respondents’ failure to answer the Requests for Admission amount to deemed admissions under Sections 1 and 2, Rule 26 of the Rules of Court?
- Were the Requests for Admission properly served on the respondents so as to trigger the deemed...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)