G.R. No. 131466 November 27, 1998
Cristina Diman, Clarissa Diman, George Diman, Felipe Diman and Florina Diman, petitioners, vs. Hon. Florentino M. Alumbres, Presiding Judge, Regional Trial Court, Las Piñas, Branch 255; Heirs of Veronica V. Moreno Lacalle, represented by Jose Moreno Lacalle, respondent.

FACTS

The Heirs of Veronica V. Moreno Lacalle filed a complaint for “Quieting of Title and Damages” against the Dimans, claiming ownership of a parcel of land in Las Piñas covered by TCT No. 273301. They alleged that Veronica Lacalle acquired the land in 1959 and retained the occupants, the Nario spouses, as caretakers. The Dimans had filed an ejectment case against the Narios, resulting in a notice to vacate and an alias writ of demolition. The Heirs asserted they were not parties to that ejectment case and sought damages.
The Dimans, in their answer, claimed to be the registered owners of the land under their own TCTs and alleged that the Heirs’ TCT No. 273301 was spurious, citing certifications from the Registry of Deeds and the Land Registration Authority that no such title existed on record.
After joinder of issues, the Dimans served a “Request for Admission” on the Heirs on February 2, 1995, asking them to admit specific facts, including that their TCT was not recorded in any relevant registry, that they could not produce a certified true copy, and that they had never paid real estate taxes on the property. The Heirs, through their counsel, received the request but failed to file any response within the period prescribed by Rule 26, and also failed to respond to a subsequent motion giving them an additional ten days to answer.
The Dimans then filed a “Motion for Summary Judgment,” arguing that due to the Heirs’ failure to respond to the Request for Admission, the matters therein were deemed admitted under Rule 26, and thus no genuine issue of fact existed. The Heirs opposed the motion, demonstrating a misunderstanding of summary judgment procedure. The Trial Court denied the motion for summary judgment, ruling that material issues of fact existed, such as the authenticity of the titles and who had better right to the property. The Dimans filed a motion for reconsideration, which was also denied.
The Dimans then filed a “Demurrer to Evidence” after the Heirs presented their evidence, arguing that the Heirs failed to prove their cause of action. The Trial Court granted the demurrer and dismissed the complaint. The Heirs appealed to the Court of Appeals, which reversed the Trial Court’s order granting the demurrer, reinstated the complaint, and remanded the case for further proceedings. The Dimans’ motion for reconsideration was denied by the Court of Appeals.

ISSUE

The core issue is whether the Heirs’ failure to respond to the Request for Admission resulted in the matters requested being deemed admitted, thereby warranting a summary judgment in favor of the Dimans and rendering further proceedings unnecessary.

RULING

The Supreme Court ruled in favor of the petitioners, the Dimans. The Court held that under Section 2 of Rule 26 of the 1964 Rules of Court (now Rule 26 of the 1997 Rules), a party’s failure to respond to a request for admission within the prescribed period results in each matter of which an admission is requested being deemed admitted. The Heirs’ complete failure to respond, despite receipt and a subsequent grace period, meant the facts in the Request for Admission were conclusively established. These deemed admissions—particularly that the Heirs’ title was not recorded, they could not produce a certified copy, and they never paid taxes—directly contradicted and destroyed the foundation of their cause of action to quiet title. Since the admissions showed the Heirs had no valid title to assert, no genuine issue as to any material fact remained. Therefore, the Dimans were entitled to a summary judgment dismissing the complaint. The Supreme Court reversed the decision of the Court of Appeals and reinstated the Trial Court’s order granting the demurrer to evidence, effectively dismissing the Heirs’ complaint.