Villuga v. Kelly Hardware
REITERATIONFacts
The Antecedents: Respondent Kelly Hardware and Construction Supply Inc. filed a Complaint for a Sum of Money and Damages against petitioners Spouses Ramon and Mercedita Villuga. Respondent alleged that petitioners purchased construction materials from November 19, 1992, to January 5, 1993, amounting to P259,809.50, which remained unpaid with stipulated interests. Despite oral and written demands, petitioners failed and refused to pay. Procedural History: Petitioners admitted making purchases but claimed they did not remember the exact amount and asserted making partial payments. They offered to pay the principal sum without interest and on installment. Respondent agreed to the principal amount but insisted on interests and expenses. Respondent filed a Motion for Partial Judgment, which the RTC deferred. Respondent filed an Amended Complaint, increasing the aggregate value to P279,809.50, with P20,000.00 paid, leaving a balance of P259,809.50. Petitioners reiterated their previous allegations. Respondent filed a Request for Admission. Petitioners filed comments, which respondent moved to expunge, arguing they were filed late and by counsel, not the parties. Respondent also moved for Summary Judgment, claiming no genuine issue of fact. The RTC granted the Motion to Expunge and rendered a Summary Judgment in favor of respondent, ordering petitioners to pay P259,809.50 with legal interest. The RTC denied petitioners' Motion for Reconsideration. The Court of Appeals affirmed the RTC's decision and resolution. Petitioners filed a petition for review on certiorari. The Petition: Petitioners argued that the Court of Appeals erred in denying their Comment and ruling that there was an implied admission, and that a summary judgment should not have been issued against them.
Issue(s)
Whether the Court of Appeals erred in denying petitioners' Comment and ruling that there was an implied admission contained in the Request for Admission. Whether a summary judgment was proper against the petitioners.
Ruling
The petition is denied. The assailed Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the first issue regarding the Request for Admission and implied admission: The Court held that the filing of respondent's Second Amended Complaint superseded only its Amended Complaint, not the Request for Admission. The Court also found that petitioners' Comments on the Request for Admission were filed out of time. However, the Court took exception to the CA's ruling that petitioners were deemed to have impliedly admitted their indebtedness solely due to the belated filing. The Court reasoned that the matters of fact in the Request for Admission were a reiteration of respondent's main allegations, which petitioners had already specifically denied in their previous pleadings. A request for admission that merely reiterates allegations already denied is inappropriate under Rule 26, as it does not serve the purpose of discovery to clarify truth or falsity. Nonetheless, the Court found that the CA was correct in sustaining the summary judgment. On the second issue regarding the propriety of the summary judgment: The Court affirmed the summary judgment. It explained that summary judgment is a procedural device to avoid prolonged litigation and is proper when there is no genuine issue as to any material fact, except for the amount of damages, and the moving party is entitled to a judgment as a matter of law. While petitioners initially raised a genuine issue of fact through their affirmative defense of partial payment, this changed with the Second Amended Complaint. In this amended complaint, respondent admitted petitioners' partial payments but alleged they were applied to other obligations, leaving the P259,809.50 balance. Petitioners failed to refute this specific allegation in their Answer to the Second Amended Complaint, instead merely reiterating their defense of partial payment and claiming lack of knowledge. The Court found it difficult to believe petitioners' claim of ignorance regarding the application of their payments, as such facts would be within their knowledge. Their failure to specifically deny or assert that the payments should be deducted from the P259,809.50 led the Court to conclude that the payments were indeed applied to other debts, leaving the principal obligation outstanding. Consequently, petitioners' defense of partial payment no longer raised genuine issues of fact requiring a full-blown trial, making the summary judgment proper.
Main Doctrine
A summary judgment is proper when the pleadings, supporting affidavits, depositions, and admissions on file show that, except as to the amount of damages, there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law. A party's failure to refute an allegation in a second amended complaint, particularly concerning the application of payments to other obligations, can lead to the conclusion that such payments were indeed applied elsewhere, leaving the principal amount sought in the complaint outstanding.