G.R. No. 176570; July 18, 2012
SPOUSES RAMON VILLUGA and MERCEDITA VILLUGA, Petitioners, vs. KELLY HARDWARE AND CONSTRUCTION SUPPLY INC., represented by ERNESTO V. YU, Executive Vice-President and General Manager, Respondent.

FACTS

Respondent Kelly Hardware filed a complaint for sum of money against petitioners Spouses Villuga, alleging unpaid purchases of construction materials amounting to P259,809.50. In their Answer, petitioners admitted making purchases but claimed partial payments of P110,301.80 and P20,000.00, leaving an uncertain balance. Respondent later filed a Request for Admission, asking petitioners to admit the genuineness of documents showing a principal obligation of P279,809.50 with only P20,000.00 paid. Petitioners filed their Comments on this Request, objecting to the documents, but their filing was delayed and the Comments were signed only by their counsel, not by the petitioners themselves.
Respondent filed a Motion for Summary Judgment, arguing that petitioners’ failure to properly and timely respond to the Request for Admission meant the matters therein were deemed admitted under the Rules of Court. The Regional Trial Court (RTC) granted the motion and rendered summary judgment in favor of respondent. The Court of Appeals affirmed the RTC’s decision. Petitioners elevated the case to the Supreme Court, contending that summary judgment was improper as their Answer had raised genuine issues of fact regarding the application of their partial payments and the exact amount owed.

ISSUE

Whether the Court of Appeals erred in affirming the grant of summary judgment in favor of the respondent.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. Summary judgment is proper when, upon the pleadings and admissions on file, no genuine issue exists as to any material fact. The legal logic centered on the consequences of petitioners’ failure to properly respond to the Request for Admission. Under the then-governing Rule 26 of the Rules of Court, a party’s failure to serve a sworn statement denying the matters requested within the period results in those matters being deemed admitted. Here, petitioners’ Comments on the Request were filed out of time and, crucially, were not sworn to by the petitioners but only by their counsel. This rendered the response a mere scrap of paper, ineffective to deny the requested admissions. Consequently, petitioners were deemed to have admitted the genuineness of the documents and the truth of the facts stated in the Request, including the principal obligation and the amount paid.
With these judicial admissions, petitioners’ defense of having made partial payments no longer presented a genuine factual issue requiring a trial. Their defense was effectively neutralized by their implied admission that the payments were applied to other obligations, as stated in the deemed-admitted documents. Since no substantial controversy remained as to the material facts, the RTC correctly rendered summary judgment. The Court emphasized that summary judgment is a procedural device to expedite litigation when the facts are not in dispute, and petitioners’ procedural misstep in responding to the Request for Admission justified its application.