Case Digest (G.R. No. 204700)
Facts:
Petitioners Eagleridge Development Corporation, Marcelo N. Naval, and Crispin I. Oben sought production and inspection of the Loan Sale and Purchase Agreement (LSPA) allegedly evidencing the price and terms of the assignment of their loan by Export and Industry Bank to Respondent Cameron Granville 3 Asset Management, Inc. The Regional Trial Court denied petitioners' motion as untimely; the Court of Appeals sustained that denial, but the Supreme Court reversed, ordered production, and respondent filed a motion for reconsideration which the Court now resolves.
Issues:
- Was the motion for production filed out of time so as to bar relief?
- Does the parol evidence rule or claimed confidentiality prevent production of the LSPA?
- Is Article 1634, New Civil Code, applicable to the assignment to an SPV under R.A. 9182, and has petitioners' right to extinguish their debt lapsed?
Ruling:
The motion for reconsideration was denied with finality. The Court held that a motion for production under Rule 27 may be filed beyond pre-trial upon a showing of good cause and that petitioners were entitled to inspect and copy the LSPA. The Court further held that the parol evidence rule and respondent's claim of confidentiality did not bar production, and that Article 1634 applies to transfers to a special purpose vehicle under R.A. 9182, with petitioners' right to extinguish not yet expired.
Ratio:
The Court reasoned that discovery rules are silent as to timing and are liberally construed to promote full disclosure; precedents permit discovery after pre-trial upon good cause. Because petitioners are not parties to the deed of assignment and they expressly put the deed's validity in issue, the parol evidence rule does not preclude production, and Rule 132, Sec. 17 permits inquiry into writings referred to by exhibits. The LSPA was not shown to fall within privileged categories of Rule 130, Sec. 24, and respondent failed to prove confidentiality. Section 13 of R.A. 9182 makes subrogation and assignment rules of the Civil Code applicable; under Article 1634 the thirty-day redemption period runs from the assignee's demand, which had not validly occurred because the assignee and consideration were not adequately disclosed.
Doctrine:
- Rule 27 motions for production or inspection may be made beyond pre-trial upon a showing of good cause.
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