Republic v. Datuin
REITERATIONFacts
The Antecedents: Petitioner Republic of the Philippines, through the Department of Environment and Natural Resources (DENR) and the Office of the Solicitor General (OSG), filed a complaint for cancellation and reversion of titles. The complaint alleged that Original Certificates of Title (OCTs) and subsequent Transfer Certificates of Title (TCTs) were fraudulently issued over land that was inalienable, based on a prior Supreme Court ruling in Republic of the Philippines v. Ayala Cia. The Republic's claim stemmed from the issuance of Fishpond Lease Agreement (FLA) No. 4718 to Prudencia V. Conlu in 1987, covering a large tract of public land. Subsequently, this land was subdivided and OCTs were issued to various individuals, who then transferred the titles to respondent corporations. The DENR later found that the area covered by these OCTs overlapped with the land covered by FLA No. 4718 and that the subdivision plan was not reflected in official maps, indicating irregularities. Procedural History: The Republic's complaint was filed with the Regional Trial Court (RTC), Branch 11, Balayan, Batangas. After some respondents filed their answers, denying the allegations and asserting the legality of the titles, respondents Baguio Pines Tower Corporation and Systemic Realty, Inc. filed a Motion for Summary Judgment, arguing that the Republic had impliedly admitted the facts and genuineness of documents due to its failure to respond to their Request for Admission. Initially, the RTC denied this motion, finding genuine issues of fact. However, upon reconsideration, the RTC granted the motion for summary judgment and dismissed the Republic's complaint, deeming the Republic to have admitted the material facts. The Republic's subsequent motion for reconsideration was denied. Aggrieved, the Republic filed a petition for certiorari with the Court of Appeals, assailing the RTC's orders. The Court of Appeals dismissed the petition, ruling that certiorari was an improper remedy and that the Republic should have filed an appeal. The Petition: The Republic seeks review of the Court of Appeals' decision via a petition for certiorari under Rule 45 of the Rules of Court. The Republic contends that the Court of Appeals erred in dismissing its petition for certiorari on a technicality, arguing that the trial court committed grave abuse of discretion amounting to excess or lack of jurisdiction by rendering summary judgment without a full trial, thereby violating its right to due process. Specifically, the Republic asserts that the trial court should not have deemed its admissions implied, as the Request for Admission merely reiterated allegations already in the pleadings and that genuine issues regarding the land's classification and the validity of the titles remained unresolved. The Republic also argues that the trial court erred in granting reconsideration and summary judgment in a single order, depriving it of due process.
Issue(s)
Whether the Court of Appeals correctly dismissed the petition for certiorari as an improper remedy against the trial court's summary judgment. Whether the trial court correctly deemed the Republic to have admitted the matters raised in respondents' request for admission and, based thereon, rendered a summary judgment against it.
Ruling
The petition is GRANTED. The Resolutions dated September 24, 2015 and April 11, 2016 of the Court of Appeals are REVERSED AND SET ASIDE. The Orders dated September 3, 2013 and December 18, 2013 of the Regional Trial Court are nullified. The RTC is directed to reopen the case, conduct pre-trial and trial, and resolve the case on the merits.
Ratio Decidendi
On the propriety of certiorari and the trial court's grave abuse of discretion: The Court held that while ordinary appeal under Rule 41 is the usual remedy against a summary judgment, a petition for certiorari under Rule 65 is proper when the trial court commits grave abuse of discretion amounting to excess or lack of jurisdiction, particularly when a party's right to due process is violated. The Court found that the trial court gravely abused its discretion when it simultaneously reconsidered its denial of the motion for summary judgment, granted the motion, and rendered summary judgment in favor of the respondents in a single order. This action deprived the Republic of its right to due process and the opportunity to seek reconsideration of the grant of the motion for summary judgment. The Court cited Paz v. Court of Appeals, Department of Education (DepED) v. Cuanan, and Spouses Leynes v. Court of Appeals to support the view that certiorari is appropriate in cases of due process violations. On the validity of the summary judgment and the Request for Admission: The Court ruled that the trial court erred in deeming the Republic to have admitted the material facts based on its failure to respond to the Request for Admission. The Court emphasized that a Request for Admission under Rule 26 is intended to clarify allegations and expedite proceedings, not to serve as a means to reiterate allegations already pleaded in the answer. The Court found that the respondents' Request for Admission merely reiterated the affirmative defenses in their Answer, making it a "delaying tactic and unjustified maneuvering." The Court cited Concrete Aggregates Corporation v. Court of Appeals and Duque v. Spouses Yu to support the principle that a party cannot be compelled to admit or deny matters already admitted or denied in previous pleadings, and the requesting party cannot rely on implied admission in such circumstances. Furthermore, the Court found that genuine issues of fact existed regarding the classification of the lots as inalienable or alienable and disposable, and the validity of the titles issued. These genuine issues necessitated a full-blown trial, and summary judgment was therefore improper. The Court reiterated that summary judgment is only proper when there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law, citing Puyat v. Zabarte.
Main Doctrine
A petition for certiorari under Rule 65 is a proper remedy to assail a summary judgment rendered by a Regional Trial Court with grave abuse of discretion amounting to excess or lack of jurisdiction, particularly when the aggrieved party's right to due process is violated. A summary judgment cannot be validly rendered if genuine issues of fact exist, and a request for admission that merely reiterates allegations in the pleadings cannot be used to compel admissions that would circumvent the need for a trial.