G.R. No. 231854 , October 6, 2020
PEOPLE OF THE PHILIPPINES, PETITIONER, VS. LEILA L. ANG, ROSALINDA DRIZ, JOEY ANG, ANSON ANG, AND VLADIMIR NIETO, RESPONDENTS.

FACTS

Respondent Leila L. Ang, an accused in Criminal Case No. 2005-1048 before the Regional Trial Court (RTC) of Lucena City, filed a Request for Admission addressed to the People, served upon the City Prosecutor. The prosecution moved to expunge it, arguing the matters were proper for pre-trial stipulation or trial evidence. The RTC initially expunged the request but, upon reconsideration by a different judge, ruled that the prosecution’s failure to respond within the 15-day period resulted in implied admissions under Rule 26 of the Rules of Court. The court subsequently declared these implied admissions as judicial admissions under Rule 129, applicable across three consolidated criminal cases against the respondents. The prosecution then filed its own Requests for Admission, which the RTC denied, reasoning that the People’s judicial admissions could no longer be contradicted.

ISSUE

The primary issue is whether the mode of discovery under Rule 26 (Request for Admission) of the Rules of Court is available and applicable in criminal proceedings.

RULING

Justice Caguioa, in his Concurring and Dissenting Opinion, concurs in the result to grant the petition but solely on the ground that the specific matters in respondent Ang’s Request for Admission were improper subjects for such a request. He vigorously dissents from the majority’s ruling that Rule 26 does not apply to criminal proceedings at all. Justice Caguioa opines that Requests for Admission should be available in criminal litigation, but only to the accused. This is premised on rectifying the inherent imbalance between the State’s vast prosecutorial resources and the accused’s severely limited access to pre-trial information. He argues that, circumscribed by the constitutional rights against self-incrimination and to remain silent, this tool cannot be made available for use by the prosecution against the accused. Furthermore, he finds a due process violation, as the Court decided the overarching applicability of Rule 26 to criminal cases without first allowing the parties to be heard on this fundamental issue, which they never raised or argued in the lower courts. The opinion emphasizes that basic fairness demanded the parties be given an opportunity to comment before the Court rendered a judgment on this novel and consequential procedural question.