Diman v. Alumbres
REITERATIONFacts
The Antecedents: The Heirs of Veronica V. Moreno Lacalle (Heirs) filed a complaint for Quieting of Title and Damages against Cristina Diman, et al. (Dimans), claiming ownership over a parcel of land based on a deed of absolute sale and a Transfer Certificate of Title (TCT) No. 273301. The Dimans, in turn, claimed ownership over their own parcels of land under TCT Nos. 90628, 90629, and 58676, and asserted that TCT No. 273301 was spurious, citing certifications from official agencies indicating no record of such title. Procedural History: The Dimans served a Request for Admission on the Heirs regarding the genuineness of their TCT No. 273301 and the registration status of titles. The Heirs failed to respond. The Dimans filed a Motion for Summary Judgment, which the Regional Trial Court (RTC) denied, stating that material issues were raised. The Heirs presented their evidence, consisting mainly of a deed of sale and Jose Lacalle's testimony, admitting they did not have the original title. The Dimans filed a Motion for Judgment on Demurrer to Evidence, which the RTC also denied, finding the deed of sale sufficient and the issues not yet fully resolved. The Dimans filed a petition for certiorari, mandamus, and prohibition in the Court of Appeals (CA), which denied their petition. The Dimans then appealed to the Supreme Court. The Petition: The Dimans sought the reversal of the CA decision, arguing that the RTC committed grave abuse of discretion in denying their motions for summary judgment and judgment on demurrer to evidence, given the Heirs' failure to respond to the Request for Admission and their lack of substantive evidence.
Issue(s)
Whether the RTC committed grave abuse of discretion in denying the motion for summary judgment. Whether the RTC committed grave abuse of discretion in denying the motion for judgment on demurrer to evidence. Whether the Heirs are deemed to have admitted the facts stated in the Request for Admission due to their failure to respond. Whether the Heirs presented sufficient evidence to establish their claim for quieting of title.
Ruling
The Supreme Court reversed and set aside the Court of Appeals' decision, annulled the RTC's orders denying the motions for summary judgment and demurrer to evidence, and dismissed the case for quieting of title and damages.
Ratio Decidendi
On the RTC's denial of the motion for summary judgment: The Court held that the RTC committed grave abuse of discretion in denying the Dimans' motion for summary judgment. The RTC's reasoning that material issues were raised because both parties claimed ownership and presented titles was deemed erroneous. The crucial question for summary judgment is whether the issues raised in the pleadings are genuine or sham, as shown by admissions, depositions, or affidavits. The Heirs' failure to respond to the Request for Admission meant that the facts stated therein were deemed admitted, rendering the issues sham and fictitious. The RTC's failure to recognize the legal consequences of the implied admissions constituted grave abuse of discretion. The Court clarified the distinction between a summary judgment and a judgment on the pleadings. A summary judgment is proper when, despite the existence of apparent issues in the pleadings, these issues are shown to be sham or fictitious through admissions, depositions, or affidavits. A judgment on the pleadings, on the other hand, is rendered when the answer fails to tender an issue. The RTC's denial of the summary judgment motion based on the existence of pleaded issues, without considering the effect of the implied admissions, demonstrated a misunderstanding of the remedy. On the RTC's denial of the motion for judgment on demurrer to evidence: The Court found that the RTC also committed grave abuse of discretion in denying the motion for judgment on demurrer to evidence. The RTC should have considered the Heirs' implied admissions from their failure to respond to the Request for Admission. These admissions, coupled with the lack of substantive evidence presented by the Heirs (such as the absence of any copy of their alleged TCT No. 273301 and the lack of proof of the vendors' ownership), demonstrated that the Heirs had shown no right to relief. The RTC's reliance on the deed of sale alone, despite its lack of reference to a Torrens title and the absence of proof of the vendors' ownership, was insufficient to overcome the implied admissions and the lack of evidence. On the effect of failure to respond to Request for Admission: The Court reiterated the doctrine that under Section 2, Rule 26 of the Rules of Court, each matter of which an admission is requested is deemed admitted if the party to whom the request is directed fails to serve a sworn statement denying the matter or setting forth reasons why it cannot be admitted or denied within the designated period. In this case, the Heirs' failure to respond to the Dimans' Request for Admission resulted in the implied admission of all the facts listed therein, including the non-existence of their TCT No. 273301 in official records and the non-payment of taxes. On the sufficiency of evidence for quieting of title: The Court found that the Heirs failed to present sufficient evidence to establish their claim for quieting of title. Their primary evidence, a deed of absolute sale, did not refer to any Torrens title and was not accompanied by proof of the vendors' ownership. Furthermore, the Heirs admitted they did not possess the original title and could not produce even a certified true copy. This lack of evidence, combined with their implied admissions regarding the spuriousness of their title and non-payment of taxes, rendered their claim unmeritorious.
Main Doctrine
The failure to respond to a Request for Admission under Rule 26 of the Rules of Court results in the implied admission of the matters requested. Courts commit grave abuse of discretion in refusing to recognize and apply the consequences mandated by law regarding discovery procedures and summary judgments when issues are sham or fictitious.