Lañada v. Court of Appeals
REITERATIONFacts
The Antecedents: During a strike declared by the Union of Filipro Employees (UFE) against Nestle Philippines, Inc. (Nestle), the National Labor Relations Commission (NLRC) issued a temporary restraining order (TRO) enjoining the UFE from blocking ingress and egress to Nestle's plant. Nestle sought assistance from the Philippine Constabulary (PC) under Capt. Rey Lañada and local police to enforce the TRO and facilitate the transfer of products using hired trucks. During the dispersal of strikers, a truck driven by Pacifico Galasao, while leaving the compound at high speed, lost control, swerved, bumped the car of Dr. Vied Vemir Garcia Hemedez, dragged it, and subsequently crashed into a house and a beauty parlor, killing two persons and severely injuring Dr. Hemedez. Capt. Lañada and PC soldiers were present but allegedly refused to unload the truck's cargo to extricate Dr. Hemedez, citing fear of looting, despite pleas from the victim's family. Dr. Hemedez died shortly after being extricated two hours later. Procedural History: The parents of Dr. Hemedez, spouses Rogelio and Eliza Hemedez, filed a civil case for damages against Nestle, its employee Francis Santos, the truck driver Galasao, Jesus Alimagno, and Capt. Lañada. During the proceedings, the Hemedez spouses served a request for admission on the defendants. The defendants, through their respective counsel, filed verified answers to the request. The Hemedez spouses filed a motion to strike out these answers, arguing that only the parties themselves, not their counsel, could answer requests for admission under Section 1, Rule 26 of the Rules of Court, and that the answers were hearsay. The Regional Trial Court (RTC) denied the motion, holding that counsel could answer for their clients and that the denials were substantial. The Hemedez spouses filed an omnibus motion for reconsideration, which the RTC denied except for the prayer to amend the complaint. The Hemedez spouses then filed a petition for certiorari with the Court of Appeals (CA), which annulled the RTC's orders, granted the motion to strike out the answers, and declared the matters as impliedly admitted. The Petition: Nestle Philippines, Inc. and Francis Santos, as well as Capt. Rey Lañada, filed separate petitions for review on certiorari, consolidated by the Supreme Court, challenging the CA's decision. The primary issue raised is whether counsel can answer a request for admission on behalf of their client.
Issue(s)
Whether an answer to a request for admission under Rule 26 of the Rules of Court, signed and sworn to by the counsel of the party, is sufficient compliance with the rules. Whether the answers filed by the defendants' counsel constituted specific denials in accordance with the rules. Whether the motion for reconsideration filed by the Hemedez spouses was timely filed.
Ruling
The Supreme Court granted the consolidated petitions, set aside the decision of the Court of Appeals, and ordered the Regional Trial Court of Laguna to proceed with the resolution of Civil Case No. B-2762 with dispatch. The Court ruled that counsel may answer requests for admission on behalf of their clients.
Ratio Decidendi
On the propriety of counsel answering requests for admission: The Court held that an answer to a request for admission under Rule 26 of the Rules of Court may be filed by the counsel of the party to whom the request is directed. This is based on the principle that attorneys have the authority to bind their clients in any case by any agreement in relation thereto made in writing and in all matters of ordinary judicial procedure, as provided in Section 23 of Rule 138 of the Rules of Court. The Court cited the case of PSCFC Financial Corporation v. Court of Appeals, which stated that Rule 26 should not be restrictively construed to mean that a party may not engage the services of counsel to make the response in his behalf. To hold otherwise would negate the principles on agency in the Civil Code and the Rules of Court. Furthermore, the Court noted that the requests for admission in this case were substantially identical to the allegations in the complaint, making the requests redundant and not intended to elicit new evidentiary matters. The Court reiterated the ruling in Po v. Court of Appeals that a party should not be compelled to admit matters of fact already admitted by his pleading or to make a second denial of those already denied in his answer to the complaint. On the specific denial of matters: While the Court upheld the propriety of counsel answering requests for admission, it also acknowledged the lower court's observation that the defendants had substantially complied with the rules by specifically denying matters they could not admit and indicating reasons why they could not admit or deny others. The Court emphasized that the veracity of these denials or uncommitted stands is a matter to be determined in a full-blown trial on the merits. On the timeliness of the motion for reconsideration: The Court found no merit in the contention that the omnibus motion for reconsideration was filed out of time. It clarified that the Order of April 10, 1989, which denied the motion to strike out the answers, was not a final order that disposed of the merits of the case. Therefore, it was not covered by the 15-day reglementary period for appeal under Section 39 of the Judiciary Reorganization Act of 1980. The motion for reconsideration was filed to address an interlocutory matter that was obstructing the expeditious disposition of the case, and the lower court had the discretion to act upon it.
Main Doctrine
An answer to a request for admission under Rule 26 of the Rules of Court may be filed by the counsel of the party to whom the request is directed, as counsel is presumed to have the authority to bind the client in matters of ordinary judicial procedure.