Case Digest (G.R. No. L-16307)
Facts:
This case, denominated G.R. No. 125383, involves two petitions for review on certiorari filed by Fortunata N. Duque and Marcosa D. Valenzuela against the Court of Appeals and the spouses Edna and Enrico Bonifacio. The case originates from the Regional Trial Court (RTC) of Valenzuela, Metro Manila. The pivotal events began with Duque filing a complaint in the RTC, alleging that the Bonifacios engaged her in negotiations involving certain checks in exchange for cash, amounting to Two Hundred Seventy Thousand Pesos (₱270,000.00). Duque alleged that the Bonifacios represented themselves as holders in due course and assured her that the checks were sufficiently funded. Upon their presentation on maturity dates, the checks were dishonored. Additionally, Duque sent notice of dishonor to the Bonifacios, who purportedly continued to refuse payment regardless of repeated demands.
Similarly, Valenzuela filed a separate complaint alleging parallel circumstances, with a total amount claime
Case Digest (G.R. No. L-16307)
Facts:
- Parties and Procedural History
- Petitioner Fortunata N. Duque and petitioner Marcosa D. Valenzuela each filed separate complaints before the Regional Trial Court (RTC) of Valenzuela.
- Duque alleged that respondents—spouses Enrico and Edna Bonifacio—negotiated with her various checks in exchange for cash, amounting to P270,000.00.
- Valenzuela alleged similar facts, involving checks totaling P432,000.00.
- The respondents denied the allegations in their Answers, specifically refuting that they negotiated such checks, represented themselves as holders in due course, or issued all of the checks mentioned.
- The respondents also claimed that any settlement arrangements were limited to checks they had duly issued, and they disputed the true extent of the alleged indebtedness.
- Allegations and Claims by the Petitioners
- The petitioners alleged that:
- The checks negotiated with them were represented as being paid for value and sufficiently funded.
- Upon presentation, the checks were dishonored, triggering a chain of events where Duque and Valenzuela gave notice of such dishonor and repeatedly demanded payment or replacement with cash.
- They supported their claims by attaching the checks as exhibits and asserting that respondents had signed promissory notes acknowledging indebtedness.
- Petitioners further asserted that letters of demand, sent on November 28, 1987 (and received on December 5, 1987), corroborated their cause of action.
- Request for Admission and RTC Pre-Trial Proceedings
- On November 22, 1988, the petitioners filed a Request for Admission addressed to the respondents, seeking admissions on matters including:
- That respondents negotiated with the petitioners for valuable consideration regarding the checks.
- That respondent Edna Bonifacio executed promissory notes (dated November 23, 1987) acknowledging indebtedness in the amounts claimed by Duque and Valenzuela.
- That the petitioners sent letters of demand dated November 28, 1987, which the respondents received on December 5, 1987.
- Due to the respondents’ failure to respond under oath to this request, the RTC, invoking Sections 1 and 2 of Rule 26 of the Rules of Court, issued an order deeming the matters admitted.
- RTC’s Decision and Subsequent Appeal
- On February 1, 1989, the RTC rendered a decision favoring the petitioners:
- It ruled that, by their failure to specifically and under oath deny the requested admissions, the respondents were deemed to have admitted the allegations.
- The decision condemned the respondents to pay the petitioners the respective amounts claimed along with legal interest from the filing of the complaint.
- Dissatisfied with this decision, the respondents elevated the case to the Court of Appeals.
- Court of Appeals Decision and Issues Raised
- On March 13, 1996, the Court of Appeals vacated and set aside the RTC decision and remanded the case for trial on the merits.
- The appellate court noted that the matters in the request for admission had already been denied in the respondents’ Answers, rendering the request redundant.
- It also held that the petitioners did not comply with the procedural requirements of Rule 26, as the request was filed in court but not served directly on the respondents.
- A subsequent motion for reconsideration by the petitioners was denied in a resolution dated May 21, 1996.
- Petition for Review on Certiorari
- Petitioner Duque filed a petition for review on certiorari under Rule 45, contesting the Court of Appeals’ decision.
- The petition assigned the following errors:
- The Court of Appeals erred in not applying Sections 1 and 2 of Rule 26 of the Rules of Court.
- The Court of Appeals erred in concluding that there was no valid service of the Request for Admission on the private respondents.
Issues:
- Whether the respondents’ failure to respond to the Request for Admission constitutes an implied admission under Sections 1 and 2 of Rule 26 of the Rules of Court.
- Petitioners argue that the lack of a sworn denial automatically implies admission of the allegations.
- Respondents maintain that the issues addressed by the Request had been previously denied in their Answers, making a further admission redundant.
- Whether the service of the Request for Admission was properly effected.
- Petitioners contend that despite being served on counsel, such service is equivalent to personal service on the respondents.
- Respondents (and the Court of Appeals) argue that direct service on the parties is required under the Rules of Court for the Request to be valid.
- The propriety of requiring respondents to respond to allegations that are already contained and denied in the pleadings.
- Petitioners justify the Request for Admission as seeking to solidify evidentiary matters crucial for establishing their cause of action or defense.
- Respondents and the appellate decision emphasize the redundancy and the absence of additional evidence beyond the pleadings.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)