G.R. No. 226130, February 19, 2018
LILIA S. DUQUE and HEIRS OF MATEO DUQUE, Petitioners, vs. SPOUSES BARTOLOME D. YU, JR. and JULIET O. YU and DELIA DUQUE CAPACIO, Respondents.

FACTS

Petitioners Lilia S. Duque and her late husband Mateo Duque were the owners of a lot in Cebu. They filed a Complaint for the declaration of nullity of a Deed of Donation over the property in favor of their daughter, respondent Delia Duque Capacio, and a subsequent Deed of Absolute Sale where Capacio sold a portion to respondent Spouses Yu. The petitioners alleged the donor’s signature was forged. Capacio admitted the forgery but denied authorship. The Spouses Yu argued the action was barred and questioned the petitioners’ personality to sue.
During proceedings, the Spouses Yu filed a Motion for Admission under Rule 26, requesting petitioners admit the genuineness of several documents, including the Deed of Donation. The trial court ordered petitioners to comment. Upon their failure to respond, the court deemed the documents admitted. Relying on this implied admission, the Spouses Yu filed a demurrer to evidence, which the trial court granted, dismissing the Complaint. The Court of Appeals affirmed, holding that the failure to reply resulted in the admission of the Deed of Donation’s authenticity, rendering the petitioners’ evidence worthless.

ISSUE

Whether the Court of Appeals erred in ruling that the petitioners’ failure to reply to the request for admission constituted an implied admission of the documents’ genuineness, warranting the dismissal of their Complaint.

RULING

The Supreme Court granted the petition and reversed the CA. The legal logic centers on the proper application of Rule 26 on requests for admission. The Court clarified that an implied admission under Section 2 of Rule 26 arises only if the party fails to respond to a request for admission regarding the genuineness of documents or truth of facts. However, a critical exception exists: when the matters subject of the request have already been specifically denied or controverted in an earlier pleading, the party cannot be compelled to admit or deny them anew, and no implied admission can arise from a failure to respond.
Here, the petitioners’ Complaint itself specifically alleged the forgery of the Deed of Donation, constituting a direct denial of its genuineness. The respondent Capacio’s Answer even admitted the forgery. Consequently, the authenticity of the Deed was already a central, contested issue joined by the pleadings. The Spouses Yu’s subsequent Request for Admission sought confirmation of the very document whose genuineness was already squarely denied. Therefore, the petitioners were not obligated to respond to this redundant request. Their silence did not constitute an implied admission under Rule 26. The trial court and the CA erred in applying the rule on implied admissions, which led to the erroneous grant of the demurrer to evidence and dismissal of the Complaint. The Supreme Court thus declared both Deeds void and ordered the restoration of the original tax declaration in the petitioners’ name.