G.R. No. 231854 - People vs. Ang

Case Summary (G.R. No. 231854)

Ang’s Request for Admission and Branch 53’s Expungement

On December 29, 2009 Ang served a detailed Request for Admission (Rule 26) on the People, seeking admissions on key audit findings and exculpatory evidence. The City Prosecutor moved to expunge it as matter for pre-trial stipulation. On April 13, 2010 RTC Branch 53 agreed and ordered the request expunged.

Transfer to Branch 56 and Admission Rulings

Upon Ang’s motion to inhibit Judge Obnamia, the cases went to RTC Lucena, Branch 56 under Judge Pastrana. In a Joint Order of February 12, 2015, the court granted partial reconsideration, held the People’s failure to timely oppose as an implied admission under Rule 26, and further deemed these as judicial admissions under Rule 129. A Motion for Clarification was denied on July 24, 2015 for lateness, reaffirming that the People’s admissions bind the case. Respondents in the other two cases adopted those admissions.

Consolidation and Further Orders

The People filed its own Requests for Admission; the three cases were consolidated May 16, 2016. In Joint Orders of March 10 and September 5, 2016, RTC Branch 56 refused to allow the People to vary the admissions—ruling that consolidation merged each case’s evidence and that the court could take judicial notice of the admissions across all three.

Sandiganbayan Proceedings

The People sought certiorari (Rule 65) before the Sandiganbayan, assailing the March 10 and September 5, 2016 Joint Orders. On March 1, 2017 the Sandiganbayan dismissed the petition, upholding the implied and judicial admissions extended by consolidation. Reconsideration was denied May 15, 2017.

Issue on Civil Discovery in Criminal Cases

The Court addressed whether Rule 26’s request for admission—designed to streamline civil trials—may apply in criminal proceedings. Under criminal procedure (1987 Constitution), parties are the People (State) and the accused. Criminal defendants enjoy a broad right against self-incrimination, including the right to refuse any testimonial compulsion or to stand silent. A request for admission would compel an admission or deem it admitted if the defendant or the State failed to answer, thus undermining these constitutional protections.

Inherent Limitations on Applying Rule 26 to Criminal Actions

The Court held:
• Parties in criminal cases (People vs. accused) cannot serve requests on each other as “adverse parties” under Rule 26. The People (via prosecutor) lack personal knowledge of documents/facts and cannot bind the State by admissions.
• Compelling an accused to answer a request for admission contravenes the right against self-incrimination and the privilege to refuse testimony altogether.
• Criminal procedure provides its own discovery safeguards—pre-trial conferences (Rule 118), conditional witness examinations (Rule 119)—making Rule 26 unnecessary and inapplicable.

Voidance of RTC’s Admissions Orders

Because Rule 26 does not apply in criminal cases, the RTC’s Joint Orders of February 12 & July 24, 2015 and March 10 & September 5, 2016 were rendered with