G.R. No. 102390 - Lanada vs. Court of Appeals

The case arose from a strike declared by the Union of Filipro Employees (UFE) against Nestle Philippines, Inc. (Nestle), alleging unfair labor practices.
A picket line was established in front of Nestle’s factory in Niugan, Cabuyao, Laguna.
On October 27, 1987, the National Labor Relations Commission (NLRC) issued a Temporary Restraining Order (TRO) enjoining the UFE and its sympathizers to desist from blocking ingress and egress points of Nestle’s plant.

To enforce the TRO, Nestle requested assistance from the 224th Philippine Constabulary (PC) Company commanded by PC/Capt. Rey LaAada, members of the Cabuyao police department, and the local fire brigade.
Nestle hired trucks owned by the Alimagno brothers for product transfer amid the strike.
On October 29, 1987, an attempt to negotiate between Alexander Asinas (UFE) and Francis Santos (Nestle) over truck movements failed when Santos signaled PC soldiers to forcibly disperse strikers.
The PC contingent, armed and assisted by fire trucks, dispersed the strikers, resulting in injuries and arrests. The trucks then left the plant despite some being hit by stones from strikers.

Dr. Vied Vemir Garcia Hemedez arrived at the site and stopped his car, unaware that a sixth overloaded ten-wheeler truck driven by Pacifico Galasao was leaving the plant at high speed.
The overloaded truck lost control, struck Dr. Hemedez’s vehicle, dragging it and overturning it.
The truck further rammed a house, a beauty parlor, and killed two persons near the scene before crashing into a chapel’s reinforced concrete wall.
Galasao exited the truck armed with a lead pipe, and his helpers armed with stones.
Dr. Hemedez was pinned under his car for about two hours before being extricated and rushed to the hospital but died shortly after due to massive intrathoracic hemorrhage from the accident.

Dr. Hemedez’s family, including his parents and siblings, arrived and sought assistance from PC/Capt. LaAada and the Alimagno brothers to unload the truck’s cargo to extricate the doctor.
LaAada and PC soldiers refused to unload the cargo immediately for fear of looting, delaying rescue efforts.
Funeral arrangements were complicated by the refusal of payment by Funeraria Dionicio, expecting the Alimagno family to pay instead.

On December 8, 1987, spouses Rogelio and Eliza Hemedez filed Civil Case No. B-2762 against Nestle, Jesus Alimagno, Francis Santos, Pacifico Galasao, and Capt. LaAada, seeking damages for Dr. Hemedez’s death and related losses.
Defendants Nestle and Santos denied liability, citing a trucking and hauling agreement with Belltown Transport Services, Inc., an independent contractor, shifting liability thereupon.
They claimed the accident occurred amid an illegal strike and was caused by the strikers’ assault on the truck. They also raised failure to implead UFE and its members and claimed the incident happened outside Nestle’s premises.
Capt. LaAada denied liability, stating efforts were exerted to save casualties and alleging that the plaintiffs misconstrued his actions as refusal to assist for their singular interest.
The defendants filed respective cross-claims and counterclaims for costs and attorney’s fees.

The Hemedez spouses served written requests for admission pursuant to Rule 26, Section 1 of the Rules of Court, requesting defendants to admit truth of various factual matters and genuineness of documents.
The answers to these requests were filed by the defendants’ counsels via verified statements.
The plaintiffs argued that only the parties themselves, not their counsel, could properly answer the request for admission, seeking to strike out the defendants’ answers on grounds of hearsay and non-compliance with Rule 26.
The trial court denied the motion to strike, reasoning that counsel acting on behalf of their clients are bound by their verified answers, and the omission was a formal defect, not jurisdictional.
Plaintiffs filed an omnibus motion seeking reconsideration, emphasizing the decisiveness of the matters requested to be admitted and requesting to amend the complaint to include additional parties. The trial court denied the omnibus motion except for the amendment of the complaint.
The plaintiffs elevated the matter via certiorari to the Court of Appeals, which reversed the trial court’s orders, striking out the answers and declaring the matters impliedly admitted.

Petitioners (Nestle, Santos, and Capt. LaAada) question the Court of Appeals ruling, especially on whether counsel may file answers to requests for admission on behalf of their clients.
Collateral issues for resolution include the sufficiency of specific denials in the answers and the timeliness of the omnibus motion.

Whether the counsel of a party to whom a written request for admission is addressed under Section 1, Rule 26 of the Rules of Court can answer such request on behalf of the client.

Whether each answer of the requested party-defendant to the statements sought to be admitted constitutes a specific denial in accordance with the rules.
Whether the motion for reconsideration of the trial court’s Order dated April 10, 1989 was timely filed.