G.R. No. L-14495 - Uy Chao vs. De la Rama Steamship Co., Inc.

The plaintiff-appellant, Vicente Uy Chao, filed a complaint on February 11, 1958, in the Court of First Instance of Manila (Civil Case No. 35269) against the defendant-appellee, De La Rama Steamship Co., Inc.
The complaint sought to collect a sum of money for purchases made by the appellee from the appellant between October 1 and December 1, 1941, plus 12% annual interest, attorney's fees, and costs.

The appellee moved to dismiss the complaint on the ground that the cause of action had prescribed.
The appellant argued that the ten-year prescriptive period had been interrupted by debt moratorium statutes (Executive Orders No. 25 and 32 and Republic Act No. 342).

The debt moratorium statutes suspended the enforcement of pre-war debts.
Republic Act No. 342, enacted on July 26, 1948, lifted the moratorium except for pre-war debtors who had filed war damage claims. For these debtors, the moratorium was extended for eight years after their claims were settled.
The Supreme Court, in Rutter vs. Esteban (93 Phil. 68), declared the further operation of Republic Act No. 342 unconstitutional and void on May 18, 1953.

The appellant contended that the prescriptive period was interrupted until May 18, 1953, due to the moratorium.
The appellee argued that the interruption ended on July 26, 1948, when Republic Act No. 342 took effect, unless the debtor was a war sufferer who had filed a war damage claim.
The trial court initially denied the motion to dismiss, stating that the issue was evidentiary and could not be determined from the complaint alone.

On July 10, 1958, the appellant served a written request for admission under Rule 23, asking the appellee to admit that it was a war sufferer and had filed a war damage claim.
The appellee moved to strike the request, arguing that it was improper at that stage since no answer to the complaint had been filed.
The trial court dismissed the complaint on July 22, 1958, ruling that the appellant failed to prove that the appellee was a war sufferer and had filed a war damage claim.

Prescription and Debt Moratorium: The prescriptive period for the cause of action was interrupted by the debt moratorium statutes. However, the interruption ended on July 26, 1948, unless the debtor was a war sufferer who had filed a war damage claim, in which case the moratorium was extended.
Burden of Proof: The burden of proving that the appellee was a war sufferer and had filed a war damage claim lay with the appellant, as it was to his advantage to claim the extended moratorium.
Request for Admission: The request for admission under Rule 23 was proper even at the pre-answer stage because the issue of whether the appellee was a war sufferer was directly relevant to the motion to dismiss. The purpose of Rule 23 is to expedite trial and avoid unnecessary proof of undisputed facts.
Liberal Construction of Rules: The rules of procedure should be liberally construed to promote their object and assist parties in obtaining a just, speedy, and inexpensive determination of every action.
Amendment of Complaint: The trial court should have allowed an amendment to the complaint to include the necessary allegations regarding the appellee's status as a war sufferer or deferred the determination of the motion until trial.