Case Summary (G.R. No. 125383)
Factual Background
The material facts are undisputed. Petitioners alleged that respondents negotiated certain checks in exchange for cash amounting to P270,000.00 in Duque’s case and P432,000.00 in Valenzuela’s case; that respondents represented themselves as holders in due course for value and represented that the checks were sufficiently funded; that upon presentment the checks were dishonored; that petitioners gave notice of dishonor and made repeated demands; and that respondents refused to honor the checks or replace them with cash. Respondents denied negotiating the checks, denied the asserted representations, denied issuing all the checks, and denied refusing to honor or replace the checks, but acknowledged making arrangements to settle checks they actually issued.
Trial Court Proceedings
After joinder of issues, the RTC issued a pre-trial order defining the principal issues, including whether defendants owed the amounts claimed and whether defendants could introduce evidence contradicting the genuineness of documents. On November 22, 1988, petitioners served Requests for Admission seeking admissions that respondents negotiated the checks for valuable consideration, that Edna Bonifacio signed promissory notes dated November 23, 1987 acknowledging indebtedness in the respective amounts, and that demand letters dated November 28, 1987 were received December 5, 1987. Respondents did not file a sworn denial to the Requests for Admission. The RTC, citing Sections 1 and 2, Rule 26, issued an order on December 27, 1988 deeming the matters admitted and, on February 1, 1989, rendered judgment in favor of petitioners in both civil cases, awarding the principal amounts with legal interest.
Court of Appeals' Ruling
The respondents appealed to the Court of Appeals, which on March 13, 1996 vacated and set aside the RTC decision and remanded the cases for trial on the merits. The appellate court held that the matters of which admission was sought by petitioners pertained to matters already denied in respondents’ Answers; that the Requests for Admission were not validly served under Section 1 of Rule 26 because they were filed in court and copies were only furnished to counsel rather than properly served on the parties themselves; and that service on counsel alone did not satisfy the statutory requirement for Requests for Admission as interpreted in Briboneria vs. Court of Appeals. A motion for reconsideration by petitioners was denied on May 21, 1996.
Issues Presented
The petition to the Supreme Court raised two issues: (1) whether respondents’ failure to respond to the Requests for Admission amounted to an implied admission under Sections 1 and 2, Rule 26; and (2) whether the Requests for Admission were validly served on the respondents such that an implied admission could be deemed to have occurred.
Parties' Contentions
Petitioners argued that the RTC correctly applied Sections 1 and 2, Rule 26, and that respondents’ failure to file a sworn denial constituted an implied admission of the requested matters. Petitioners further contended that service on respondents’ counsel sufficed as service on the respondents themselves, relying on precedent such as PSFC Financial Corp. vs. Court of Appeals. Respondents maintained that they denied the matters in their Answers and that the Requests for Admission were not properly served upon them in the manner required by the rule.
Supreme Court's Analysis
The Court reviewed Section 1 and Section 2 of Rule 26, observing that the rule allows a party to request admission of genuineness of documents or truth of relevant matters of fact and that lack of a timely sworn denial results in deemed admission. The Court emphasized the remedial purpose of the rule to obtain admissions of evidentiary matters to expedite trial or facilitate settlement, and warned that requests that merely reproduce allegations already traversed in pleadings are pointless and redundant. The Court examined each of the three categories of requested admissions. It found that the request that respondents negotiated the checks was substantially the same as allegations already made and expressly denied in respondents’ Answers, so a further admission was superfluous. The request that Edna Bonifacio executed promissory notes was defective because petitioners failed to attach copies of the promissory notes to the Requests for Admission and did not show prior or simultaneous service of such documents as required by Section 1. The request concerning receipt of demand letters was likewise unnecessary in view of the complaint’s allegations and the respondents’ denial.
Sufficiency of Service
The Court addressed service and held that petitioners served copies of the Requests for Admission only on respondents’ counsel, Atty. H.G. Domingo, Jr. The Court noted the general rule that notices and pleadings are served upon counsel, but it recognized the exception when the law expressly requires personal service upon a definite person. Applying Briboneria vs. Court of Appeals, the Court concluded that the Requests for Admission under Rule 26 must be served upon the party in the manner the rule prescribes and that service on counsel alone did not constitute valid service of
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Case Syllabus (G.R. No. 125383)
Parties and Procedural Posture
- Fortunata N. Duque and Marcosa D. Valenzuela, assisted by her husband, Abelardo Valenzuela, were petitioners who instituted separate civil actions in the RTC of Valenzuela and thereafter filed a petition for review under Rule 45 before the Supreme Court.
- Spouses Enrico and Dra. Edna Bonifacio were private respondents in the underlying civil actions and respondents to the petition.
- The RTC of Valenzuela rendered judgment on February 1, 1989, deeming certain matters admitted and awarding judgment for petitioners in Civil Cases Nos. 2756-V-88 and 2757-V-88.
- The Court of Appeals vacated and set aside the RTC decision and remanded the cases for trial on the merits in its Decision dated March 13, 1996.
- The petitioners sought reversal of the Court of Appeals decision and reinstatement of the RTC judgment.
Key Factual Allegations
- Petitioners alleged that respondents negotiated certain checks in exchange for cash totaling P270,000.00 (Duque) and P432,000.00 (Valenzuela).
- Petitioners alleged that respondents represented themselves as holders in due course and for value and affirmed that the checks were sufficiently funded.
- Petitioners alleged that upon presentation the checks were dishonored, that they gave notice of dishonor, and that respondents refused repeated demands to honor or replace the checks.
- Respondents disputed having personally negotiated the checks, disputed representing that they were holders in due course or that the checks were sufficiently funded, and disputed the total amounts alleged.
Pleadings and Admissions
- The RTC issued a pre-trial order on June 28, 1988 defining the principal issues and setting the cases for trial on the merits.
- Petitioners filed Requests for Admission on November 22, 1988 seeking admissions that respondents negotiated the checks, that Edna Bonifacio signed promissory notes dated November 23, 1987 acknowledging indebtedness, and that demand letters dated November 28, 1987 were received on December 5, 1987.
- Respondents did not file sworn denials or objections to the Requests for Admission within the period designated.
- The RTC, citing Section 1 and Section 2, Rule 26 of the Rules of Court, issued an order on December 27, 1988 deeming the requested matters admitted for failure to respond.
Trial Court Proceedings
- The RTC entered judgment on February 1, 1989, finding the requested matters deemed admitted and condemning respondents jointly and severally to pay P270,000.00 to Duque and P432,000.00 to Valenzuela with legal interest from filing of the complaints.
- The RTC declared the cases submitted for decision following the implied admissions.
Court of Appeals Ruling
- The Court of Appeals vacated and set aside the RTC judgment and remanded the cases for trial on the merits in its March 13, 1996 Decision.
- The Court of Appeals reasoned that the matters of which admissions were sought were already denied in respondents' Answers and that the Requests for Admission were filed in court but were not served directly on the appellants as required under the rule.
- The Court of Appeals relied on the Supreme Court precedent in Briboneria vs. Court of Appeals, 216 SCRA 607, to conclude that service on counsel alone did not satisfy the service requirement where the rule required personal service.
Issues Presented
- The principal