People v. Ang
NEW DOCTRINEFacts
1. The Antecedents: Respondents Leila L. Ang, Rosalinda Driz, Joey Ang, Anson Ang, and Vladimir Nieto were charged with Falsification of Public Documents, Malversation of Public Funds, and Violation of Section 3(e) of RA 3019 (Anti-Graft and Corrupt Practices Act). Leila Ang, an officer of the Development Bank of the Philippines (DBP)-Lucena City, and Rosalinda Driz, a DBP teller, were found to have conspired with Joey Ang, Anson Ang, and Vladimir Nieto, owners of certain construction and supply companies, in defrauding the DBP of P4,840,884.00. This was allegedly done by unlawfully crediting cash deposits to the accounts of the companies without actual deposit or with lesser amounts, and by concealing a cash shortage through fictitious journal entries. 2. Procedural History: The Deputy Ombudsman for Luzon found probable cause and recommended the indictment of the respondents. Three Informations were filed before the Regional Trial Court (RTC) of Lucena City, Branch 53. Initially, the RTC denied Leila Ang's Request for Admission. However, upon inhibition of the presiding judge and transfer of the cases to Branch 56, the new presiding judge granted Ang's motion for partial reconsideration, ruling that the prosecution's failure to deny the request within the prescribed period deemed the facts impliedly admitted. The RTC later denied the prosecution's motion for clarification and declared the implied admissions as judicial admissions. The People then filed a Petition for Certiorari before the Sandiganbayan, assailing the RTC's orders. 3. The Petition: The Sandiganbayan dismissed the People's petition for certiorari, finding no palpable error in the RTC's rulings, and noting infirmities in the petition itself, such as lack of proper verification and questionable authority of the counsel. The People, through a Petition for Review on Certiorari under Rule 45, now seeks to reverse the Sandiganbayan's decision. The People argue that the consolidation of the cases did not extend the effect of implied admissions to other cases, that implied admissions under Rule 26 are limited to the pending action, and that such admissions are not judicial admissions under Rule 129. They also question the Sandiganbayan's conclusion regarding the authority of the deputized counsel.
Issue(s)
Whether the Request for Admission under Rule 26 of the Rules of Civil Procedure is applicable in criminal proceedings. Whether the consolidation of the three criminal cases extended the effect of implied admissions to all cases. Whether the Joint Orders of the RTC, which declared implied admissions as judicial admissions, were void for having been issued with grave abuse of discretion. Whether Atty. Michael Vernon De Gorio was authorized to file the petition for certiorari before the Sandiganbayan.
Ruling
The Supreme Court granted the petition, reversed and set aside the Decision and Resolution of the Sandiganbayan, and declared the Joint Orders of the RTC void. The Court directed the RTC to continue the trial proceedings with reasonable dispatch.
Ratio Decidendi
On the applicability of Request for Admission in criminal proceedings: The Court ruled in the negative. It explained that while modes of discovery in civil procedure may be applied suppletorily in criminal cases, Rule 26 (Request for Admission) is not applicable. The Court reasoned that a request for admission can only be served on an adverse party, and in criminal cases, the State is the real party-in-interest, which cannot be privy to the execution of documents or acquire personal knowledge of factual events in the same way a natural person can. Furthermore, compelling an accused to respond to a request for admission would violate their constitutional right against self-incrimination, as failure to respond would be deemed an admission, and the sworn statement required could expose them to perjury. The Court emphasized that pre-trial procedures, such as stipulation of facts, serve a similar purpose without infringing upon fundamental rights. On the effect of consolidation: The Court held that the consolidation of the three criminal cases was for joint trial purposes under Section 22, Rule 119 of the Rules of Court, not for actual consolidation resulting in a merger of evidence under Section 1, Rule 31. Therefore, the consolidation did not extend the effect of implied admissions from one case to the others. The Court reiterated that admissions obtained under Rule 26 are for the pending action only and cannot be used in any other proceeding. On the voidness of the RTC's Joint Orders: The Court found that the RTC committed grave abuse of discretion in allowing the Request for Admission under Rule 26 in criminal proceedings, disregarding established rules and jurisprudence. Such orders are considered void and have no legal effect. The Court clarified that even though the accused, Leila Ang, initiated the request, it was still improper in a criminal context, as it sought to compel the prosecution to admit facts that were the burden of the prosecution to prove or the defense to establish. The Court noted that the RTC's orders effectively closed the case for the prosecution before trial, leading to an acquittal without due process. On the authority of Atty. De Gorio: The Court found that Atty. De Gorio, as a deputized special prosecutor by the Ombudsman, was authorized to file the petition for certiorari before the Sandiganbayan. The Court interpreted the deputization to be in force until the termination of proceedings, which includes appeals and special civil actions assailing lower court decisions, not strictly limited to the trial court level. The SB's restrictive interpretation was deemed erroneous.
Main Doctrine
Requests for admission under Rule 26 of the Rules of Civil Procedure are not applicable in criminal proceedings due to inherent limitations and potential violation of the accused's right against self-incrimination. Any order issued by a lower court allowing such requests in criminal cases is void for having been issued with grave abuse of discretion.