G.R. No. 186979 ; August 11, 2010
Socorro Limos, Rosa Delos Reyes and Spouses Rolando Delos Reyes and Eugene Delos Reyes, Petitioners, vs. Spouses Francisco P. Odones and Arwenia R. Odones, Respondents.

FACTS

Respondents Spouses Odones filed a complaint for Annulment of Deed, Title and Damages against petitioners. They claimed ownership of a parcel of land by virtue of an Extrajudicial Succession of Estate and Sale executed by certain heirs of the original owner, Donata Lardizabal. Upon attempting to register this document, they discovered that the land’s Original Certificate of Title had already been cancelled and replaced by a Transfer Certificate of Title (TCT) in the petitioners’ names. Petitioners derived their title from a 1972 Deed of Absolute Sale allegedly executed by Donata Lardizabal and her husband. Respondents alleged this deed was a forgery, as both purported vendors were already deceased at the time of its execution.
In their Answer, petitioners raised affirmative defenses, including failure to state a cause of action, non-joinder of indispensable parties, and laches. They subsequently served a Request for Admission upon respondents, seeking admissions regarding the heirs of Donata Lardizabal and the validity of the respondents’ own document of title. Respondents failed to respond to this request. Petitioners then filed a Motion to Set for Preliminary Hearing the Special and Affirmative Defenses, arguing that the failure to respond constituted an implied admission of the matters requested, thus making a preliminary hearing on the defenses imperative.

ISSUE

Whether the trial court correctly denied the Motion to Set for Preliminary Hearing the Special and Affirmative Defenses despite respondents’ failure to respond to the Request for Admission.

RULING

Yes. The Supreme Court affirmed the rulings of the lower courts denying the motion. The legal logic is that a motion for a preliminary hearing on affirmative defenses is addressed to the sound discretion of the trial court. The court’s denial is not subject to review unless a grave abuse of discretion is shown, which was not present here. More critically, the Court clarified that the purpose of a Request for Admission under Rule 26 is to simplify trials by establishing facts about which there is no genuine issue. It is not intended to compel admissions of legal conclusions or to prove the truth of disputed facts central to the case.
The matters in petitioners’ Request for Admission went to the very heart of the controversy—the validity of the respondents’ title and the identity of the true heirs. These are ultimate facts or mixed questions of fact and law that are properly the subject of a full trial on the merits, not of summary admission. Respondents’ failure to reply did not automatically render the requested matters admitted for the purpose of a summary dismissal. The trial court correctly determined that the substantive issues raised in the affirmative defenses, including the alleged defect in respondents’ cause of action, required a full presentation of evidence. Therefore, a preliminary hearing was unnecessary, and the case must proceed to trial to thresh out the factual and legal disputes.