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

This case originated from three consolidated criminal cases for violation of the Tariff and Customs Code. Accused Leila Ang filed an “Amended Accused’s Request for Admission by Plaintiff” in Criminal Case No. 2005-1048. In a Joint Order dated February 12, 2015, the Regional Trial Court (RTC) of Lucena City granted Ang’s motion and deemed the facts in her request as impliedly admitted by the prosecution due to its failure to respond within the 15-day period under Rule 26 of the Rules of Court. The RTC later denied the prosecution’s motion for clarification. Subsequently, Ang manifested her adoption of these implied admissions in the two other related criminal cases. When the prosecution later filed its own Requests for Admission in the consolidated cases, the RTC denied them via Joint Orders dated March 10, 2016 and September 5, 2016, ruling that the People’s prior implied judicial admissions could no longer be contradicted. The Sandiganbayan affirmed these orders.

ISSUE

Whether a request for admission under Rule 26 of the Rules of Court is applicable and proper in criminal proceedings.

RULING

The Supreme Court, through the ponencia and concurring opinions, ruled that a request for admission under Rule 26 is inapplicable to criminal cases. Justice Inting, in his Concurring Opinion, concurred with the ponencia’s disposition to declare null and void the RTC’s Joint Orders dated February 12, 2015, July 24, 2015, March 10, 2016, and September 5, 2016. The legal logic is clear: Rule 26 is a mode of discovery designed for civil actions where issues are joined after pleadings are filed, a procedural stage absent in criminal cases. Its application in criminal proceedings contravenes constitutional safeguards, particularly the right against self-incrimination, as it could compel the prosecution to admit or deny facts under pain of implied admission, thereby improperly shifting the burden. Furthermore, criminal procedure already provides adequate mechanisms for defining and simplifying issues, such as the pre-trial conference under Rule 118, which is the proper venue for obtaining stipulations and admissions. The use of Rule 26 requests in this context was a procedural misstep that introduced unnecessary complexity and delay. Consequently, the Court granted the petition and directed the RTC to resume proceedings with dispatch.