GR 153034; (September, 2005) (Digest)
G.R. No. 153034 September 20, 2005
DEVELOPMENT BANK OF THE PHILIPPINES, Petitioner, vs. HONORABLE COURT OF APPEALS and ROSALINDA CANADALLA-GO, represented by her Attorney-in-fact BENITO A. CANADALLA, Respondent.
FACTS
Respondent Rosalinda Canadalla-Go filed a complaint against petitioner Development Bank of the Philippines (DBP) concerning the redemption price of foreclosed properties. After DBP filed its Answer, Go served a Request for Admission under Rule 26. DBP filed a Comment on the request, but it was not under oath. During a hearing, Go moved to have the matters deemed impliedly admitted, arguing the response lacked the required oath under Section 2, Rule 26. DBP countered that the matters in the request were mere reiterations of the allegations in the Complaint, which had already been specifically denied or admitted in its verified Answer. DBP later submitted an affidavit from its counsel to cure the defect. The Regional Trial Court granted Go’s motion, declaring the matters impliedly admitted. The Court of Appeals affirmed, ruling the unsworn comment was non-compliant and the subsequent affidavit was filed too late.
ISSUE
Whether the matters in the Request for Admission, which were mere reiterations of allegations already specifically denied in a verified Answer, may be deemed impliedly admitted due to a subsequent unsworn response to the request.
RULING
The Supreme Court ruled in favor of DBP and reversed the appellate court. The legal logic is that a Request for Admission is intended to simplify trials by establishing matters not in dispute. It is not intended for matters already addressed in the pleadings. Here, the matters sought to be admitted were identical to the allegations in the Supplemental Complaint, to which DBP had already filed a verified Answer containing specific denials and admissions. To require a party to admit or deny again, under oath, the very same allegations already squarely met in the pleadings would be pointless and superfluous. The Court emphasized that the rule on implied admissions should not be applied mechanically to defeat substantial justice. Since the issues had already been joined by the verified Answer, the purpose of the request was served, and DBP’s subsequent unsworn comment did not warrant a declaration of implied admission. The technical defect was inconsequential given the prior verified pleading that had already put the matters in issue.