Duque v. Yu
REITERATIONFacts
The Antecedents: Lilia S. Duque and her late husband, Mateo Duque, were the registered owners of a 7,000-square meter lot. They alleged that they executed a Deed of Donation for this property in favor of their daughter, Delia D. Capacio. Capacio subsequently sold a portion of this property to respondents Spouses Bartolome D. Yu, Jr. and Juliet O. Yu. The Spouses Duque filed a complaint seeking to declare the Deed of Donation and the subsequent Deed of Absolute Sale as null and void, asserting that the signature on the Deed of Donation was forged. They also sought to cancel the tax declaration in the name of Juliet Yu and reinstate the tax declaration in Mateo Duque's name. Procedural History: The Spouses Duque filed a Verified Complaint before the Regional Trial Court (RTC) of Barili, Cebu. During the proceedings, the Spouses Yu filed a Motion for Admission requesting the admission of several documents, including the Deed of Donation and the Deed of Absolute Sale. The Spouses Duque failed to comment on this motion, leading the RTC to deem the documents admitted. Subsequently, the Spouses Yu filed a demurrer to evidence, which the RTC granted, dismissing the Complaint. The Spouses Duque appealed to the Court of Appeals (CA), which affirmed the RTC's decision. The CA ruled that the failure to respond to the request for admission resulted in an implied admission of the documents' authenticity. The Spouses Duque then filed a petition for review on certiorari with the Supreme Court. The Petition: The petitioners, Lilia S. Duque and the heirs of Mateo Duque, filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court. They assail the Decision and Resolution of the Court of Appeals, arguing that the CA erred in holding that their failure to reply to the request for admission constituted an implied admission of the authenticity and genuineness of the documents. Furthermore, they contend that the dismissal of their Complaint based on an improper application of the rule on implied admission would result in unjust enrichment at their expense. The petition highlights that the forgery of the Deed of Donation was the core of their original complaint and that the authenticity of the document was already controverted in their earlier pleadings.
Issue(s)
Whether the petitioners' failure to respond to the Request for Admission resulted in an implied admission of the genuineness and authenticity of the Deed of Donation. Whether the trial court erred in granting the demurrer to evidence based on the supposed implied admission, and the validity of the Deed of Donation and subsequent sale.
Ruling
The petition is impressed with merit. The Court reversed and set aside the CA Decision and Resolution, granted the petitioners' Complaint, declared both the Deed of Donation and Deed of Absolute Sale void, cancelled the Tax Declarations in the names of respondents Capacio and Juliet O. Yu, and restored the Tax Declaration in the name of Mateo Duque, et al.
Ratio Decidendi
On the issue of implied admission: The Court held that failure to respond to a request for admission does not result in an implied admission if the matters sought to be admitted have already been denied or controverted in an earlier pleading. In this case, the forgery of the Deed of Donation was the very essence of the Spouses Duque's Complaint. Therefore, they were not required to respond to the request for admission, and they could not be deemed to have admitted the Deed of Donation's genuineness and authenticity. The Court further noted that the respondents Spouses Yu themselves had alleged forgery in a criminal case and used a PNP report certifying the forgery, making their request for admission a sham. The rule on implied admission under Section 2, Rule 26 of the Rules of Court admits of an exception when the matters in the request for admission have already been denied or controverted in previous pleadings. The requesting party cannot reasonably expect a response and then demand the application of the implied admission rule if the matters have already been addressed. On the issue of the demurrer to evidence, and the validity of the Deed of Donation and subsequent sale: The Court ruled that since there was no implied admission of the Deed of Donation's genuineness and authenticity, it was an error for the trial court to grant the demurrer to evidence. The demurrer was anchored on the supposed implied admission, which the Court found to be non-existent. Consequently, the Orders granting the demurrer were deemed void. The Court then proceeded to rule on the merits of the Complaint based on the petitioners' evidence, which included the testimony of a handwriting expert and the Answer of respondent Capacio, both confirming the forgery. The Court concluded that the Deed of Donation, being a falsified document, was void and inexistent. As a consequence, respondent Capacio could not validly transfer any right over the property, and the subsequent Deed of Absolute Sale was also without force and effect, applying the principle of "Nemo dat quod non habet."
Main Doctrine
Failure to respond to a request for admission does not result in implied admission if the matters sought to be admitted have already been denied or controverted in a prior pleading. Consequently, a demurrer to evidence based on such supposed implied admission should be denied.