G.R. No. 110495 January 29, 1998
PRODUCERS BANK OF THE PHILIPPINES, petitioner, vs. THE HON. COURT OF APPEALS, (TENTH DIVISION), HON. JESUS O. IBAY, Presiding Judge of Branch 30, Regional Trial Court of Manila, and STATE INVESTMENT HOUSE, INC., respondents.

FACTS

Private respondent State Investment House Inc. (SIHI) filed a complaint for sum of money against petitioner Producers Bank of the Philippines (PBP) involving two causes of action: for unpaid interest on five certificates of time deposit (CTDs) and for the principal amount covered by two other CTDs (Nos. 5793 and 5794). PBP’s defense regarding CTDs 5793 and 5794 was that they were issued in the name of a certain Johnny Lu and that payment had already been made to him. After PBP presented its evidence and SIHI presented rebuttal evidence, SIHI served written interrogatories upon PBP, seeking information related to Johnny Lu and the bank’s former branch manager, to ascertain details about the alleged payment and the circumstances of the CTDs’ pre-termination. PBP filed a motion to quash the interrogatories on the ground that they were improper since the trial was about to be terminated. The trial court denied the motion, admitting the interrogatories to help facilitate early disposition and assist in determining the truth. The Court of Appeals dismissed PBP’s special civil action for certiorari, citing that the Rules do not provide a time frame for filing depositions and modes of discovery.

ISSUE

Whether the trial court was correct in allowing the admission of the written interrogatories by SIHI at the rebuttal stage of the proceedings.

RULING

Yes, the trial court was correct. The petition is denied. The Supreme Court affirmed the decision of the Court of Appeals. The Rules of Court do not provide a specific time frame within which modes of discovery, such as written interrogatories, must be availed of, other than requiring leave of court after jurisdiction is obtained or without leave after an answer has been served. The purpose of discovery is to ascertain every bit of useful information for trial preparation, to prevent surprise, and to ensure mutual knowledge of relevant facts. The trial court enjoys considerable discretion in matters pertaining to discovery. In this case, the interrogatories related to the factual and principal issues in dispute (the defense of payment to Johnny Lu) and their admission would help expedite the disposition by circumscribing rebuttal evidence. The Supreme Court found no grave abuse of discretion by the trial court, as its action did not adversely affect the substantial rights of PBP, who could still present its own rebuttal. The conclusions of the trial court, being in a better position to examine evidence, are entitled to great weight.