Concrete Aggregates Corporation v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Concrete Aggregates Corporation (petitioner) engaged the services of private respondent Vivien S. Soriguez (private respondent) for its Cebu plant site. Petitioner terminated private respondent's services, alleging dissatisfaction due to a failure to prevent and promptly investigate a theft case. Private respondent filed an action for collection of unpaid fees, claiming unlawful termination and seeking moral damages. Petitioner contended that its refusal to pay was justified by losses incurred from a theft, asserting legal set-off or compensation. Procedural History: Petitioner sent private respondent a Request for Admission regarding her responsibility for a theft. Private respondent filed a Manifestation and Reply, which was not under oath. Petitioner filed a Motion for Summary Judgment, arguing that private respondent impliedly admitted the matters in the request by failing to respond under oath. The trial court denied the motion, stating that the rules could be relaxed in the interest of justice and that summary judgment was improper due to factual issues. The Court of Appeals affirmed the trial court's decision. The Petition: Petitioner elevated the matter to the Supreme Court, questioning the ruling that private respondent's unverified response did not constitute an implied admission and that summary judgment was inappropriate.
Issue(s)
Whether Rule 26 of the Revised Rules of Court requires a party to respond to a Request for Admission of matters raised in his pleadings. Whether failure to place under oath denials in a response to a Request for Admission constitutes an admission of the matters sought to be admitted. Whether the denial of the Motion for Summary Judgment was proper.
Ruling
The petition is denied. The Court of Appeals and the Regional Trial Court did not commit reversible error.
Ratio Decidendi
On whether Rule 26 requires a response to a Request for Admission of matters raised in pleadings: The Court held that Rule 26 contemplates interrogatories that clarify and shed light on the truth or falsity of allegations in a pleading, not a mere reiteration of what has already been alleged. A request that merely reproduces affirmative defenses and counterclaims already stated in an answer constitutes an utter redundancy and a useless process. In such instances, the party receiving the request is not compelled to admit matters already admitted by their pleading or concerning which there is no issue, nor should they be required to make a second denial of those already denied in their answer. Furthermore, a party should not be made to deny matters already averred in their complaint. On whether failure to place denials under oath constitutes admission: The Court ruled that a Request for Admission is not intended to merely reproduce allegations of the requesting party's pleading but should set forth relevant evidentiary matters. Since the petitioner's Request for Admission contained the same material averments as its Answer, which were already controverted by private respondent's verified Complaint, private respondent was not required to reply. Even assuming a response was needed, the Court found that private respondent's Manifestation and Reply substantially complied with the requirement of denial, as it clearly showed her intent to deny the matters. The defect of not being under oath was considered a formal, not substantive, defect that could be dispensed with in the interest of substantial justice, aligning with the principle of liberal construction of pleadings. On the propriety of denying the Motion for Summary Judgment: The Court affirmed the lower courts' denial of the motion for summary judgment. It reiterated that summary judgment cannot take the place of trial when genuine issues of fact exist between the parties. The dispute over whether private respondent was liable for the stolen articles and for violating her contract for security services involved factual issues that could only be resolved through a full-blown hearing. Until these factual disputes were determined by presentation of evidence, no legal compensation could take place between the parties.
Main Doctrine
A Request for Admission under Rule 26 of the Rules of Court contemplates interrogatories that clarify allegations in pleadings and does not refer to a mere reiteration of what has already been alleged. A response not under oath to such a request, if it substantially denies the material allegations, may be considered as a denial, and a formal defect of not being under oath may be dispensed with in the interest of substantial justice, especially when genuine issues of fact exist.