G.R. No. 126134 - People vs. De la Cuesta y Pararas

Case Summary (G.R. No. 126134)

Relevant Facts (narrowed to discovery dispute context)

During post-strike events, an overloaded truck driven by Pacifico Galasao left Nestle’s premises, lost control, fatally injured Dr. Hemedez, and caused other property damage and deaths. The Hemedez spouses filed suit against multiple parties, including Nestle, its agents, the truck driver, and Capt. Laaada. The plaintiffs served requests for admission on the defendants; answers verified and filed by the defendants’ counsel prompted a motion by the plaintiffs to strike those answers on the ground that only the party, not counsel, may properly verify and serve such responses.

Trial Court Rulings

The trial court denied the plaintiffs’ motion to strike the defendants’ counsel-verified answers, reasoning that counsel’s verification imposes upon counsel the same undertaking as would personal verification by the party, that verification is formal rather than jurisdictional, that defendants are bound by acts of their counsel, and that the denials were substantially compliant. The trial court later denied an omnibus motion except to allow amendment to implead additional parties.

Court of Appeals Ruling

The Court of Appeals annulled the trial court orders, granted the motions to strike the answers to the requests for admission, declared the matters requested to be admitted by implication, and remanded the case to the RTC for appropriate proceedings.

Supreme Court’s Analysis on Counsel-Verifications

The Supreme Court held that a party may, through counsel, answer requests for admission. The Court relied on principles of agency and on prior decisions (notably PSCFC Financial Corp. v. Court of Appeals) which interpret the phrase “the party to whom the request is directed” to allow responses made by an authorized attorney. The Court noted Rule 138 provisions that attorneys are presumed authorized to represent clients and have authority to bind clients in ordinary judicial procedure. Because there was no showing that counsel lacked authority to verify the answers, the counsel’s verification was permissible.

Supreme Court’s Analysis on Redundancy and Service

Although counsel may respond, the Court reaffirmed that requests for admission must serve their discovery purpose and should not be redundant of pleadings. A request that merely reproduces allegations already in pleadings is improper. The Court also reiterated that requests must be served directly upon the party requested; failure to serve the party personally may justify denying motions that treat served counsel’s responses as defective. The application of discovery rules and sanctions for noncompliance remain within the sound discretion of the trial court.

On Specific Denials and Trial Court Discretion

The Supreme Court emphasized that whether an answer constitutes a specific denial as required by Rule 26 is a matter for the trial court to determine in the context of the entire case and the evidence to be developed at trial. The veracity and sufficiency of denials cannot be conclusively adjudicated on an interlocutory motion; they are issues to be examined in a full trial where parties can support their respective positions.

On Timeliness of Omnibus Motion for Reconsideration

The petitioners argued the omnibus motion was untimely under Section 39 of the Judiciary Reorganization Act (15-day period for appeals from final ord

Case Syllabus (G.R. No. 126134)

Procedural Posture

Two consolidated petitions for review on certiorari questioned the Court of Appeals Decision dated July 24, 1991 that resolved negatively the issue whether counsel may answer, on behalf of a party, a written request for admission under Section 1, Rule 26 of the Rules of Court.
The petitions arose from Civil Case No. B-2762 filed in the Regional Trial Court (RTC) of Laguna by spouses Rogelio and Eliza Hemedez for damages resulting from a vehicular accident that killed their son, Dr. Vied Vemir Garcia Hemedez.
After the Hemedez spouses served requests for admission, answers verified and filed by defendants’ counsel were moved to be struck out by plaintiffs; RTC (Judge Minita Chico-Nazario) denied the motion to strike in an Order dated April 10, 1989.
The plaintiffs filed an omnibus motion for reconsideration, which the RTC denied on July 24, 1989 except for permitting amendment of the complaint to implead additional parties.
The Hemedez spouses filed a petition for certiorari on August 16, 1989 (docketed G.R. No. 89399), referred by the First Division to the Court of Appeals (docketed CA-G.R. No. 18894).
The Court of Appeals, by Decision dated July 24, 1991, annulled the RTC’s April 10 and July 24, 1989 Orders, granted the motions to strike out the answers to the requests for admission, declared the matters impliedly admitted, and remanded the case to the RTC.
The consolidated petitions for review on certiorari — involving G.R. Nos. 102390 and 102404 — were subsequently brought to the Supreme Court, which rendered the present decision authored by Justice De Leon, Jr.

Facts

The Union of Filipro Employees (UFE) declared a strike against Nestle Philippines, Inc. (Nestle) and established a picket line in front of Nestle’s Cabuyao, Laguna plant.
On October 27, 1987, the NLRC issued a temporary restraining order (TRO) enjoining the UFE, its sympathizers and agents from blocking, barricading, and obstructing ingress and egress to Nestle’s Cabuyao plant.
To enforce the TRO and clear gate access, Nestle sought assistance from the 224th Philippine Constabulary (PC) Company in Camp Eldridge, Los Baños, Laguna, commanded by PC/Capt. Rey Lañada (spelled LaAada in the source), the Cabuyao police department under P/Maj. Lorenzo T. Malaga, and the Cabuyao fire brigade.
Nestle hired trucks owned by the Alimagno brothers (Constancio, Jr. — Officer-in-Charge of Cabuyao — and Jesus) to transfer products from the Cabuyao factory to Nestle’s Taguig warehouse during the strike.
On October 29, 1987, Alexander Asinas (UFE) and Francis Santos (Nestle) agreed to constitute a panel to discuss the trucks and scabs, but in apparent bad faith Santos signaled the PC contingent to disperse strikers and allowed overloaded cargo trucks to exit the plant.
The PC contingent, in uniform and plain clothes and armed with armalites, used truncheons and were assisted by fire trucks’ water cannons; fourteen (14) strikers were arrested and many were injured during the dispersal.
Five (5) trucks successfully left the compound despite some windshields being broken by stones. A sixth ten-wheeler truck owned by Jesus Alimagno and driven by Pacifico Galasao began leaving the compound at full speed.
Dr. Vied Vemir Garcia Hemedez arrived in his Ford Escort 4-door sedan, model 1975, plate No. DOG-689, returning from a masteral class at the University of the Philippines College of Public Health; he stopped his car near the scene.
Galasao, driving in a crouched position to avoid stones and controlling a long, overloaded truck, lost control after turning onto the national road; the truck zigzagged, reached a soft shoulder, swerved, and could not be brought back on course.
The truck went diagonally across to the left side of the road, hit and dragged Dr. Hemedez’s car until it turned upside down, side-swept a house, rammed down a beauty parlor, ran over and killed two persons near the beauty parlor, and finally crashed into the Iglesia ni Cristo chapel’s reinforced concrete wall and post.
Galasao alighted from the truck and armed himself with a lead pipe while helpers armed themselves with stones; PC Captain Lañada and PC soldiers rushed to the truck to prevent looting.
Dr. Hemedez, pinned under his overturned car, pleaded for people to extricate him and for his parents to be informed; his brothers Roel and Emeterio and mother Eliza Hemedez arrived and attempted to rescue him.
Roel cut ropes holding the truck’s canvass and asked PC soldiers to unload the cargo; Capt. Lañada refused to unload for fear of looting; Mrs. Hemedez and Jesus Alimagno were also refused when they asked to unload the cargo.
It took two (2) hours before the cargo was unloaded onto other trucks, after which Dr. Hemedez was pulled from under the truck and brought to Perpetual Help Hospital in Biñan, Laguna, where he died shortly after arrival.
Cause of death was stated as “Intra-thoracic hemorrhage, massive, due to severe impact (Vehicular Accident).”
The Hemedez family attempted to pay Funeraria Dionicio for funeral services, but its owner Dionicio Hemedez refused payment because Miguela Alimagno, mother of Jesus, undertook to pay.

Pleadings, Requests for Admission, and Responses

On December 8, 1987, spouses Rogelio and Eliza Hemedez filed Civil Case No. B-2762 in the RTC of Laguna against Nestle, Jesus Alimagno, Francis Santos, Pacifico Galasao, and PC/Capt. Rey Lañada, seeking damages including:
- P30,000.00 as indemnity for Dr. Hemedez’s death;
- P11,400,000.00 representing loss of earnings;
- P80,000.00 as actual compensation for destruction of the car;
- moral and exemplary damages; and attorney’s fees.
Nestle and Santos, in their answer, denied liability and pleaded the existence of a “trucking and hauling agreement” with Belltown Transport Services, Inc., an independent contractor that assumed liability for injuries and damages; they also alleged the accident occurred during an illegal strike and blamed the strikers’ violent assault on the truck as proximate cause.
Capt. Lañada denied liability and described the incident as caused by a monstrous traffic jam from an unruly mob; he defended his and his men’s acts as efforts to protect the larger throng and interposed a counterclaim for moral damages and attorney’s fees.
The Hemedez spouses served the defendants a request for admission as to the truth of the facts in their complaint and the genuineness of appended documents.
Verified answers to the requests for admission were filed by defendants through their respective counsel (Nestle and Santos through counsel, Capt. Lañada, and Alimagno and Galasao likewise).
Plaintiffs moved to strike out the defendants’ answers on the ground that Section 2 of Rule 26 requires the parties themselves to personally