G.R. No. 117574. January 2, 1997.
Concrete Aggregates Corporation, petitioner, vs. The Honorable Court of Appeals, Hon. Priscila S. Agana, Regional Trial Court of Cebu City, Branch 24, and Vivien S. Soriguez, respondents.

FACTS

Petitioner Concrete Aggregates Corporation retained the security services of private respondent Vivien S. Soriguez for its Cebu plant. In November 1991, petitioner terminated the contract, alleging dissatisfaction with the services due to respondent’s failure to prevent and investigate a theft. In October 1992, respondent filed a collection case for unpaid fees and claimed damages for unlawful termination. Petitioner countered that respondent was answerable for the theft losses, asserting a legal compensation or set-off between the claimed unpaid fees and the value of the stolen items.
Subsequently, petitioner served a Request for Admission seeking respondent’s admission of responsibility for the theft. Respondent, through counsel, filed a Manifestation and Reply specifically denying the allegations in the request, but the document was not under oath. Petitioner then moved for summary judgment, arguing that under Rule 26 of the Rules of Court, the failure to serve a sworn response constituted an implied admission of the facts in the request. The trial court and the Court of Appeals denied the motion, prioritizing substantive rights over technicalities and noting the existence of factual issues requiring a full trial.

ISSUE

Whether a party is required to respond under oath to a Request for Admission that merely reiterates matters already raised in the pleadings, and whether the failure to do so constitutes an implied admission.

RULING

The Supreme Court denied the petition, upholding the denial of the motion for summary judgment. The legal logic is twofold. First, the Request for Admission was improper under Rule 26. The primary function of a request for admission is discovery—to clarify and shed light on the truth of allegations, not to merely reiterate what is already pleaded. A cursory examination showed petitioner’s request simply recopied the affirmative defenses and counterclaims from its Answer. It was an utter redundancy seeking to make respondent deny her own verified Complaint and admit petitioner’s Answer, a pointless process to which a party should not be subjected.
Second, even assuming a response was required, the sworn verification was a formal, not a substantive, defect. Respondent’s unsworn Manifestation and Reply constituted a substantial compliance, as it clearly expressed an intent to deny the allegations. Procedural rules may be relaxed in the interest of justice, especially where, as here, genuine issues of fact exist regarding respondent’s liability for the theft and the validity of the claimed compensation. Summary judgment is improper when facts are disputed, as these issues necessitate a full trial on the merits for resolution.