GR 156178; (January, 2006) (Digest)
G.R. No. 156178; January 20, 2006
PHILIPPINE NATIONAL BANK and ASSET PRIVATIZATION TRUST, Petitioners, vs. REFRIGERATION INDUSTRIES, INC., Respondent.
FACTS
Respondent Refrigeration Industries, Inc. (RII) occupied a portion of the assembly plant of Delta Motor Corporation (DMC). In 1984, petitioner Philippine National Bank (PNB) foreclosed on DMC’s properties and took possession of the entire DMC compound, including chattels claimed by RII. RII demanded the release of its properties, but PNB refused, citing lack of proof of ownership. RII filed a complaint for Recovery of Possession with Damages. Subsequently, some of the contested properties were transferred to petitioner Asset Privatization Trust (APT). During the proceedings, RII filed a Motion for Summary Judgment, attaching a PNB letter dated May 11, 1989, stating the contested chattels belonged to RII and were erroneously transferred to APT, and an APT letter dated May 29, 1989, acknowledging the mistake and agreeing to release the properties.
ISSUE
Was the grant of summary judgment by the trial court, affirmed by the Court of Appeals, proper given the alleged existence of a genuine issue regarding ownership of the chattels?
RULING
Yes, the summary judgment was proper. Summary judgment is appropriate when, based on the pleadings and admissions, no genuine issue as to any material fact exists. A “genuine issue” is one that requires the presentation of evidence. Here, the core issue of ownership was rendered non-genuine by petitioners’ own admissions. PNB’s letter explicitly admitted RII’s ownership and the erroneous transfer. APT’s letter confirmed this admission and agreed to release the properties. Under Section 8, Rule 8 of the Rules of Court, the genuineness and due execution of these written instruments are deemed admitted if not specifically denied under oath. Petitioners failed to make such a specific denial under oath. Consequently, the letters stood as judicial admissions, removing any substantial factual dispute regarding ownership. The purpose of summary judgment is to expedite litigation by weeding out sham claims or defenses. Since the material fact of ownership was established by petitioners’ uncontroverted admissions, the trial court correctly dispensed with a trial. The Court of Appeals did not err in affirming the summary judgment.