Case Summary (G.R. No. 167330)
Petitioner’s Claims and Trial Court Proceedings
Respondent’s complaint alleged that between November 19, 1992 and January 5, 1993, petitioners purchased materials worth P259,809.50, which remained unpaid despite repeated demands. Petitioners admitted the purchases and partial payments totalling P130,301.80, offered to pay the principal alone on installment, and denied knowledge of the exact balance. Respondent filed successive amended complaints, adjusting purchase dates and acknowledging petitioners’ payments, yet asserting a P259,809.50 balance. A Request for Admission sought to establish the genuineness of invoices, statements of account, delivery receipts, and petitioners’ indebtedness. Petitioners’ comments were filed late and objected to on formality grounds. Respondent then moved to expunge those comments and for summary judgment, which the RTC granted, entering judgment for P259,809.50 plus legal interest.
Issues on Review
- Whether petitioners’ late comments to the Request for Admission should have been accepted and whether their delay resulted in implied admission of indebtedness.
- Whether summary judgment was improper given alleged genuine issues of material fact, specifically regarding partial payment.
Applicable Law
Under the 1987 Philippine Constitution, the relevant procedural rules are:
• Section 8, Rule 10 (effect of amended pleadings)
• Rule 26 (requests for admission)
• Rule 35 (summary judgment)
Ruling on Request for Admission
The Court affirmed that respondent’s Second Amended Complaint did not withdraw the earlier Request for Admission per Section 8, Rule 10, and that petitioners’ comments, filed beyond the ten-day period mandated by Section 2, Rule 26, were properly expunged. However, the Supreme Court held that an implied admission was unwarranted because the Request merely restated allegations already specifically denied in prior pleadings. Under Rule 26, a request duplicating an earlier denial is improper; the correct response is an objection based on redundancy, not a fresh denial.
Ruling on Summary Judgment
Pursuant to Rule 35, summary judgment is proper when pleadings, admissions, and supporting materials show no genuine issue of material fact and entitle the mova
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Facts
- On March 3, 1995, respondent (Kelly Hardware) filed with the RTC of Bacoor, Cavite a Complaint for a Sum of Money and Damages against petitioners (Spouses Villuga).
- Allegation: Between November 19, 1992 and January 5, 1993, petitioners purchased construction materials worth P259,809.50; neither principal nor stipulated interest has been paid.
- Respondent made several oral and written demands for payment, all allegedly ignored by petitioners.
- Prayer:
- P259,809.50 principal plus 14% per annum interest;
- P64,952.38 attorney’s fees plus P500 appearance fee;
- P26,000 for litigation and related expenses;
- costs of suit.
Petitioners’ Admissions, Denials, and Offers
- Petitioners admitted making purchases but could not recall exact amounts due to absence of attached documentation.
- Claimed payments on March 4, 1994 (P110,301.80) and August 9, 1994 (P20,000), and offered to pay the balance after verification.
- Manifestation dated July 18, 1995: willing to pay P259,809.50 in principal only, in installments, without interests and costs to “buy peace.”
- Respondent’s Counter-Manifestation: agreed to principal payment but insisted on interest, litigation expenses, attorney’s fees, and incidental expenses.
Early Procedural Motions
- August 11, 1995: respondent moved for Partial Judgment on the Pleadings, arguing petitioners implicitly admitted owing P259,809.50 by asserting partial payments totaling P130,301.80.
- RTC Order of September 11, 1995 deferred resolution, finding no clear and specific admission as to the exact amount owed.
- January 30, 1996: respondent filed Amended Complaint, with leave of court, adjusting aggregate purchases to P279,809.50 and acknowledging P20,000 paid, leaving P259,809.50 balance.
- Petitioners filed Answer to Amended Complaint, reiterating partial payment defense.
Discovery: Request for Admission
- March 8, 1996: respondent filed Request for Admission, seeking petitioners’ a