G.R. No. 130243 October 30, 1998
ROBERTO DELA TORRE, ET AL., petitioners, vs. PEPSI COLA PRODUCTS, PHILS., INC. and PEPSICO INC., respondents.
FACTS
Petitioners are holders of softdrink bottle caps bearing the number 349, allegedly a winning digit in a contest sponsored by respondents. Due to respondents’ refusal to deliver the prizes, petitioners filed eight separate complaints for specific performance and damages in the Regional Trial Court (RTC) of Makati. Petitioners filed motions to litigate as paupers (in forma pauperis). Respondent PI sent written interrogatories to petitioners, consisting of 59 questions aimed at determining their eligibility to litigate as paupers, covering details of employment, business, income, and property ownership. The RTC issued an order suspending proceedings until petitioners could complete documents for their pauper status. Petitioners did not answer the interrogatories, believing the court’s order suspended all matters except those directly related to submitting pauper qualification papers. Respondent PI moved to dismiss the case based on petitioners’ refusal to make discovery. The RTC granted the motion to dismiss, stating its order did not authorize ignoring the interrogatories and that the answers would reflect eligibility to litigate as paupers. The Court of Appeals affirmed the RTC’s dismissal order.
ISSUE
Whether the Court of Appeals committed grave error in affirming the dismissal of the complaints based on petitioners’ failure to serve answers to interrogatories concerning their pauper status, and whether petitioners had substantially complied with the requirements.
RULING
The Supreme Court reversed the decision of the Court of Appeals and remanded the case to the RTC for trial. The Court held that dismissal is a severe sanction for refusal to make discovery and should be used sparingly, only in extreme cases of contumacious refusal to comply with court orders. Petitioners’ failure to answer was due to a good faith misapprehension of the scope of the RTC’s suspension order, not intransigence. The written interrogatories pertained to a collateral matter (pauper status) and not the main merits of the case. The trial court should have first ordered petitioners to answer the interrogatories, with a warning of consequences for non-compliance, and dismissal would only be justified if they bucked such an order. The circumstances warranted a liberal application of the rules, and petitioners should be given a chance to substantiate their claim.