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

Case Summary (G.R. No. 231854)

Factual Background

Respondents were charged after a DBP special audit disclosed alleged cash shortages and fictitious ledger entries at DBP‑Lucena Branch, resulting in a claimed loss totaling PHP 4,840,884.00. The Deputy Ombudsman found probable cause to file three separate criminal informations: falsification of public documents, malversation under Article 217, and violation of Section 3(e) of R.A. 3019. Respondent Leila Ang was a DBP document analyst and general ledger system user; respondent Rosalinda Driz was a branch teller; respondents Joey Ang, Anson Ang, and Vladimir Nieto were persons and entities alleged to have benefited from irregular crediting of CASA accounts.

Trial Court Proceedings

Respondent Leila Ang filed an Amended Accused’s Request for Admission under Rule 26 in Criminal Case No. 2005‑1048. The Office of the City Prosecutor of Lucena moved to expunge the Request for Admission as improper in criminal proceedings. RTC‑Lucena Branch 53 initially denied and ordered expungement on April 13, 2010. After judicial transfers, Judge Dennis R. Pastrana of Branch 56 granted partial reconsideration on February 12, 2015 and ruled that, because the prosecution failed to deny or oppose within the fifteen‑day period, the matters in the Request were deemed impliedly admitted under Section 2, Rule 26 and were also judicial admissions under Section 4, Rule 129. The RTC denied a timely motion for clarification and later, upon consolidation of the three cases for trial, declined the People’s Requests for Admission on the ground that the People’s judicial admissions could no longer be contradicted.

Petition to the Sandiganbayan and Its Ruling

The People filed a petition for certiorari under Rule 65 before the Sandiganbayan challenging the RTC’s Joint Orders that treated the implied admissions as judicial admissions and applied them to the consolidated cases. The Sandiganbayan dismissed the petition on March 1, 2017, holding that consolidation extended the effect of the implied admissions to the other cases and that any RTC errors were errors of judgment, not jurisdictional errors correctible by certiorari. The Sandiganbayan also noted alleged defects in the petition’s verification and questioned the authority of Atty. De Gorio to file the petition.

Issues Presented and the Parties’ Contentions

The People urged the Supreme Court to reverse the Sandiganbayan on several grounds, principally that: (a) the RTC gravely abused its discretion by treating a Rule 26 Request for Admission as binding judicial admissions across separate informations; (b) Rule 26 admissions are for the pending action only and cannot be used against the People in other proceedings; (c) implied admissions under Rule 26 are nonverbal and cannot be judicial admissions under Rule 129; and (d) Atty. De Gorio was authorized to represent the People by deputization from the Ombudsman under R.A. 6770, Section 31. Respondent Leila Ang opposed the petition as untimely and defended the RTC’s rulings, arguing that the admission procedure and pretrial stipulation mechanisms applied and that the RTC correctly construed consolidation for joint trial to permit the adoption of admissions across the related cases. Other respondents adopted Ang’s positions.

Ruling of the Supreme Court

The Supreme Court granted the petition, reversed and set aside the Sandiganbayan Decision dated March 1, 2017 and Resolution dated May 15, 2017, declared the RTC Joint Orders dated February 12, 2015, July 24, 2015, March 10, 2016, and September 5, 2016 void, and directed RTC‑Lucena Branch 56 to continue the trial proceedings in Criminal Case Nos. 2005‑1046, 2005‑1047, and 2005‑1048 with reasonable dispatch.

Legal Basis and Reasoning — Applicability of Modes of Discovery in Criminal Proceedings

The Court examined whether civil discovery devices, particularly Rule 26 requests for admission, are suppletorily applicable in criminal proceedings. The Court surveyed prior jurisprudence on the limited suppletory application of civil discovery in criminal cases and distinguished cases allowing certain depositions or conditional examinations only in exceptional circumstances under Rule 119 and Section 15 thereof. The Court emphasized that criminal proceedings are primarily governed by the Revised Rules of Criminal Procedure and that suppletory civil discovery cannot abridge substantive criminal protections.

Legal Basis and Reasoning — Why a Request for Admission is Inapplicable in Criminal Cases

The Court articulated three central reasons why a Request for Admission under Rule 26 is not applicable to criminal proceedings. First, Rule 26 presupposes service upon and answer by an adverse party in possession of personal knowledge; in criminal cases the adverse party is the State—the People—represented by a public prosecutor who lacks first‑hand, sensory personal knowledge of the facts and documents such that any response would be hearsay. Second, Rule 26’s operation would contravene the accused’s constitutional right against self‑incrimination under Art. III, Sec. 17, 1987 Constitution because the rule compels an adverse party to file a sworn statement or suffer deemed admissions, thereby effectively forcing the accused to become a witness against himself and exposing him to perjury peril. Third, the nature and objectives of criminal prosecutions—where the prosecution must at all times prove guilt beyond reasonable doubt and the accused may invoke a right to remain silent—render Rule 26 inappropriate; pretrial stipulation mechanisms under Rule 118 and the criminal rules on conditional examination under Rule 119 furnish appropriate procedural vehicles without violating constitutional guarantees. The Court stressed that, in the particular facts, respondent Ang’s Request for Admission contained chiefly defensive matters and allegations going to the elements of the offenses, and its adoption would have the effect of foreclosing the prosecution and prematurely terminating the People’s case.

Application to the Instant Case

Applying these principles, the Court held that the RTC erred gravely in admitting and treating as judicial admissions the matters in respondent Ang’s Request for Admission and in applying those deemed admissions to the other criminal informations. Because a Request for Admission is not a proper mode of discovery in criminal proceedings, the four RTC Joint Orders that admitted, treated as judicial admissions, or relied upon those admissions were issued with grave abuse of discretion and were therefore void. The Court further held that, given this conclusion, it need not resolve subsidiary issues concerning consolidation and service.

Deputization and Authority to Represent the People

The Court addressed the Sandiganbayan’s concerns about Atty. Michael Vernon De Gorio’s authority. It construed the Deputization/Authority to Prosecute issued by OMB‑Luzon as authorizing Atty. De Gorio to represent the People in proceedings relative to the criminal cases so long as the trial court proceedings remained pending. The Court therefore found that Atty. De Gorio was duly deputized to file the certiorari petition and to sign the certificate of non‑forum shopping on behalf of the People.

Disposition

The Supreme Court reversed and set aside the Sandiganbayan Decision and Resolution, declared void the RTC Joint Orders of February 12, 2015, July 24, 2015, March 10, 2016, and September 5, 2016, and directed RTC‑Lucena Branch 56 to proceed with trial in Criminal Case Nos. 2005‑1046, 2005‑1047 and 2005‑104

Case Syllabus (G.R. No. 231854)

Parties and Posture

People of the Philippines filed a Petition for Review on Certiorari under Rule 45, Rules of Court assailing the Sandiganbayan Decision dated March 1, 2017 and Resolution dated May 15, 2017.
Leila L. Ang, Rosalinda Driz, Joey Ang, Anson Ang, and Vladimir Nieto were respondents in three criminal cases originating from an Ombudsman finding of probable cause.
The petition sought annulment of several Regional Trial Court orders that deemed certain matters in a Request for Admission as implied and judicial admissions and that applied those admissions across related criminal cases.
The Supreme Court granted the petition, reversed and set aside the Sandiganbayan rulings, declared the challenged RTC orders void, and directed the RTC to resume trial proceedings with reasonable dispatch.

Key Facts

A DBP special audit pursuant to DBP SL Memorandum Order No. 99-007 found an alleged cash shortage and a purported concealment by entries in the General Ledger including an entry denominated “Due From Other Banks.”
The Ombudsman found probable cause and sought indictment for falsification of public documents, malversation under Art. 217, Revised Penal Code, and violation of Section 3(e) of RA 3019 amounting to P4,840,884.00.
Leila L. Ang was the DBP-Lucena Document Analyst and authorized Branch General Ledger System user, while Rosalinda Driz was a branch teller and the other respondents were alleged beneficiary account owners.
Leila L. Ang filed an Amended Accused’s Request for Admission dated December 29, 2009 seeking admissions from the People on numerous factually detailed defenses.

Procedural History

The Ombudsman filed three Informations before the RTC of Lucena, Branch 53, on November 10, 2005.
The Office of the City Prosecutor of Lucena moved to expunge Ang’s Request for Admission on the ground that its matters were proper pre-trial stipulations or evidentiary matters.
The RTC initially ordered expungement on April 13, 2010, but after motions and transfer it granted partial reconsideration on February 12, 2015 and deemed the matters in the Request for Admission impliedly admitted under Section 2, Rule 26.
The RTC denied a timely Motion for Clarification and ruled on July 24, 2015 that the implied admissions were also judicial admissions under Section 4, Rule 129.
The accused and co-accused manifested adoption of the deemed admissions across the related criminal cases and the People later filed their own Requests for Admission.
The RTC issued joint orders on March 10, 2016 and September 5, 2016 taking judicial notice of the admissions and denying the People’s Requests for Admission.
The People filed a petition for certiorari under Rule 65 before the Sandiganbayan, which dismissed it, and the People then elevated the matter to the Supreme Court under Rule 45.

Issues Presented

Whether a Request for Admission under Rule 26, Rules of Civil Procedure is applicable in criminal proceedings.
Whether implied admissions in one criminal case may be treated as judicial admissions and applied to related or consolidated criminal cases.
Whether the deputized counsel, Atty. Michael Vernon De Gorio, had authority to represent the People before the Sandiganbayan.
Whether the RTC committed grave abuse of discretion in treating the Request for Admission as creating admissions binding on the People.

Petitioner's Contentions

The People contended that the RTC erred by treating the Request for Admission as creating admissions beyond the single pending action because Section 3, Rule 26 limits the effect of admissions to the pending action only.
The People argued that the consolidation sought was for joint trial under Section 22, Rule 119 and not an “actual consolidation” merging evidence under Section 1, Rule 31.
The People maintained that implied admissions under Rule 26 are nonverbal and not equivalent to judicial admissions under Rule 129.
The People asserted that Atty. De Gorio was duly deputized by the Ombudsman and was authorized to file the certiorari petition while proceedings in the RTC remained pending.

Respondents' Contentions

Leila L. Ang argued the petition was filed late and that the Solicitor General’s receipt marked the start of the period for extensions.
Respondents contended that the modes of discovery, including Rule 26, apply to criminal cases pursuant to Section 3, Rule 1 of the Rules of Court.
Respondents maintained that the RTC properly deemed the Request for Admission as implied admissions and that adoption of such admissions in related cases was permissible upon consolidation for joint trial.
Respondents raised technical objections to the People’s petition based on verificat