Motor Service Co. v. Yellow Taxicab Co.
REITERATIONFacts
The Antecedents: Plaintiff Motor Service Co., Inc. filed a complaint against defendants Yellow Taxicab Co., Inc. and Felipe Monserrat to recover P1,842.55, representing an outstanding balance for automobile spare parts and merchandise bought on credit. The plaintiff alleged that the account was overdue and stipulated for 12% annual interest and 25% attorney's fees in case of suit. Defendant Monserrat had allegedly assumed joint and several liability. Procedural History: Defendants filed an answer admitting some allegations but denying the correctness of the itemized statement and invoices, claiming they were still checking them. Subsequently, the plaintiff served a request for admission on the defendants. The defendants failed to respond to this request within the ten-day period. Based on this failure, the plaintiff filed a motion for summary judgment. The Appeal: The defendants appealed the decision of the Court of First Instance of Manila, which rendered a summary judgment against them. Their main arguments were that they were not bound to comment on the request for admission because they had already filed an answer, and that the motion for summary judgment was defective for not being supported by affidavits.
Issue(s)
Whether the defendants' failure to respond to the request for admission, despite having filed an answer, constitutes an admission of the facts stated therein. Whether a motion for summary judgment is fatally defective if not supported by affidavits when the material facts are deemed admitted due to a failure to respond to a request for admission.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance. The defendants were sentenced jointly and severally to pay the plaintiff the sum of P1,842.55, plus 12% annual interest and 25% of the amount due as attorney's fees, with costs.
Ratio Decidendi
On Issue 1: The Court held that the defendants' failure to respond to the plaintiff's request for admission within the ten-day period resulted in the matters contained therein being deemed admitted, as per Rule 23, Section 2 of the Rules of Court. This rule is absolute and applies regardless of whether an answer has already been filed. The Court clarified that the denials in the defendants' answer were conditional ('still checking') and not absolute, further weakening their position. The purpose of the request for admission is to shorten litigation by clarifying the genuine issues, and inaction on such a request prevents this objective from being achieved. Therefore, the plaintiff's claim stood undisputed due to the defendants' admission. On Issue 2: The Court ruled that the motion for summary judgment was not fatally defective. While Section 1 of Rule 36 of the Rules of Court requires supporting affidavits, these were deemed superfluous in this case. The defendants' failure to answer the request for admission meant that all material facts necessary for a judgment in favor of the plaintiff were already a matter of record and admitted. The Court cited former Chief Justice Moran, stating that depositions or admissions of parties are superior to affidavits and can be used instead. Thus, the lack of separate affidavits did not invalidate the summary judgment.
Main Doctrine
The Supreme Court affirmed the decision of the Court of First Instance, holding that the defendants' failure to respond to the plaintiff's request for admission constituted an admission of the facts presented therein. This procedural consequence, as provided by Rule 23, Section 2 of the Rules of Court, meant that the plaintiff's claim stood undisputed, justifying a summary judgment. The Court emphasized that a request for admission can be served at any time and that the obligation to respond is mandatory, regardless of whether an answer has already been filed.