Briboneria v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a parcel of land and a residential house located at 59 Amsterdam Street, Provident Village, Marikina, Metro-Manila, registered under Transfer Certificate of Title No. N-29859 in the names of Salvador D. Briboneria (petitioner) and his wife, Nonita A. Briboneria. The petitioner claims he acquired these properties through his earnings abroad and that his wife, without his authorization, sold the property to Gertrudes B. Mag-isa (private respondent) via a Deed of Absolute Sale. The petitioner alleges he never authorized the sale, was denied the use and enjoyment of his properties, and suffered mental anguish and damages as a result. He sought annulment of the sale and damages. 2. Procedural History: The petitioner filed a complaint for Annulment of Document and Damages with the Regional Trial Court (RTC) of Pasig. After the parties joined issues, the petitioner served a request for admission on the private respondent's counsel. The private respondents filed an Answer to Request for Admission. Subsequently, the petitioner filed a Motion for Summary Judgment, arguing that the private respondents had admitted the facts due to a late and unsworn answer. The RTC initially denied this motion, then granted reconsideration, and then set aside that order, ultimately setting the case for pre-trial. Aggrieved by the RTC's order of February 1, 1989, the petitioner filed a petition for certiorari, prohibition, and mandamus with the Court of Appeals (CA). The CA dismissed this petition on August 13, 1990, and denied the subsequent motion for reconsideration. 3. The Petition: The petitioner filed a petition for review on certiorari with the Supreme Court, assailing the CA's decision. He argued that the CA erred in holding that the matters and documents requested for admission were mere reiterations of the complaint and that the private respondents had impliedly admitted them due to their failure to respond within the prescribed period and the unsworn nature of their response. The petitioner contended that the requested matters were relevant evidentiary matters supporting his cause of action. The Supreme Court denied the petition, affirming the CA's decision. The Court found that the requested matters were indeed reiterations of the complaint and that, crucially, the request for admission was served on the private respondent's counsel, not directly on the party, rendering the service invalid under Rule 26 of the Rules of Court.
Issue(s)
Whether the Court of Appeals erred in holding that the matters of fact and documents requested to be admitted were mere reiterations of those alleged in the complaint. Whether the private respondents impliedly admitted the material facts and documents subject to the request for admission due to their failure to answer within the fixed period and the answer not being under oath. Whether the request for admission was validly served upon the private respondent's counsel.
Ruling
The petition is denied. The decision of the Court of Appeals dated 13 August 1990 is affirmed.
Ratio Decidendi
On the issue of whether the matters requested for admission were mere reiterations of the complaint: The Supreme Court affirmed the Court of Appeals' finding that the material matters and documents set forth in the request for admission were the same as those alleged in the complaint, which the private respondents had already admitted or denied in their answer. The Court reiterated the principle that a request for admission is not intended to merely reproduce or reiterate allegations of a pleading but should set forth relevant evidentiary matters of fact or documents whose purpose is to establish a party's cause of action or defense. Therefore, compelling a party to admit matters already admitted or denied in their pleading would be redundant and contrary to the purpose of the rule. On the issue of implied admission due to failure to answer and the answer not being under oath: The Supreme Court held that for a party to be deemed to have admitted the genuineness of any relevant document or relevant matters of fact due to failure to answer a request for admission, the request must be served directly upon the party. Since the request in this case was served upon the counsel for the private respondent, not directly on the respondent herself, the private respondent could not be deemed to have admitted the facts and documents subject of the request for admission. On the issue of the validity of service of the request for admission: The Supreme Court definitively ruled that under Section 1, Rule 26 of the Rules of Court, a request for admission must be served directly upon the party. The Court distinguished this from the general rule of service upon counsel for notices and other papers filed with the court, explaining that requests for admission are intended to operate extra-judicially and do not require court filing. Therefore, service upon counsel, as was done in this case, was not valid service, and consequently, no admission could be deemed to have occurred based on the failure to answer.
Main Doctrine
A request for admission must be served directly upon the party, not their counsel, to be considered validly served, and failure to answer does not lead to an admission if service was improper.