G.R. No. 176885 - Republic vs. EspiNo.

This case involves petitioners Socorro Limos, Rosa Delos Reyes, Spouses Rolando Delos Reyes and Eugene Delos Reyes versus respondents Spouses Francisco P. Odones and Arwenia R. Odones.
The respondents filed a complaint for Annulment of Deed, Title, and Damages (Civil Case No. 05-33) before the Regional Trial Court (RTC) of Camiling, Tarlac, Branch 68.

Respondents claimed ownership of a 940-square meter property located in Pao 1st, Camiling, Tarlac, based on an Extrajudicial Succession of Estate and Sale dated January 29, 2004 executed by surviving grandchildren and heirs of Donata Lardizabal. The heirs named were Soledad Razalan Lagasca, Ceferina Razalan Cativo, Rogelio Lagasca Razalan, and Dominador Razalan.
When respondents attempted to register their title, they discovered that the Original Certificate of Title (OCT) was cancelled on April 27, 2005 and replaced by Transfer Certificate of Title (TCT) No. 329427, which was issued in favor of petitioners.
Petitioners allegedly secured TCT No. 329427 via a Deed of Absolute Sale dated April 18, 1972, executed by Donata Lardizabal and her husband Francisco Razalan. Subsequently, petitioners subdivided the property and secured three new TCTs (Nos. 392428, 392429, and 392430) in their names.

Respondents alleged that the signatures of Donata Lardizabal and Francisco Razalan on the 1972 Deed of Absolute Sale were forgeries, pointing out that Donata and Francisco died in 1926 and 1971, respectively.
Petitioners filed a Motion for Bill of Particulars claiming ambiguity in respondents’ assertion that their vendors were the sole heirs of Donata Lardizabal; this motion was denied.
Petitioners raised multiple affirmative defenses in their Answer, including (a) failure to state a cause of action due to formal defects and invalidity of respondents’ claim of ownership based on the Extrajudicial Succession of Estate and Sale, (b) non-joinder of indispensable parties (other heirs), and (c) laches by respondents.

Respondents submitted a sworn statement of Amadeo Razalan identifying the heirs of Donata Lardizabal and denying any sale to petitioners by certain heirs.
Petitioners issued a Request for Admission covering facts about familial relationships, the validity of heirs, and prior documents, to which respondents failed to respond.
Petitioners then moved to set a preliminary hearing on their special and affirmative defenses, arguing respondents’ failure to respond implied admission under Rule 26, Section 2 of the Rules of Court.
The RTC denied this motion and its subsequent motion for reconsideration, stating that the matters were already raised and denied in previous pleadings, rendering the Request for Admission redundant.
The Court of Appeals (CA) affirmed the RTC decisions, ruling that the affirmative defenses were not indubitable and required full trial.

Petitioners sought review by the Supreme Court, arguing that respondents’ failure to respond to the Request for Admission admitted the facts, necessitating a preliminary hearing per the Court’s earlier ruling in Gochan v. Gochan.

Whether respondents’ failure to answer the Request for Admission constituted implied admissions under Rule 26, Section 2 of the Rules of Court, warranting a preliminary hearing on petitioners’ affirmative defenses.

Whether the trial court erred in denying petitioners’ Motion to Set for Preliminary Hearing the Special and Affirmative Defenses.

Whether the complaint filed by respondents stated a valid cause of action for annulment of title.

Whether the non-joinder of other heirs of Donata Lardizabal was a ground for dismissal of the complaint.

Whether the status of heirs of Donata Lardizabal should be established first in a special proceeding before any civil action.