GR 231854 Leonen (Digest)
G.R. No. 231854 . October 06, 2020
PEOPLE OF THE PHILIPPINES, PETITIONER, VS. LEILA L. ANG, ROSALINDA DRIZ, JOEY ANG, ANSON ANG, AND VLADIMIR NIETO, RESPONDENTS.
FACTS
This case involves the propriety of serving a request for admission under Rule 26 of the Rules of Civil Procedure in criminal proceedings. The specific procedural context arises from a criminal case where such a request was at issue. The core legal question pertains to identifying the proper parties upon whom this mode of discovery may be served, considering the unique nature of a criminal action which is prosecuted in the name of the People of the Philippines.
ISSUE
Whether a request for admission under Rule 26 of the Rules of Civil Procedure can be validly served on the public prosecutor or the accused in a criminal case.
RULING
No. Justice Leonen, in his Separate Concurring Opinion, clarifies that a request for admission cannot be served on the public prosecutor or the accused. The legal logic proceeds from the distinct parties and interests in a criminal case. A criminal action is prosecuted under the control of the public prosecutor representing the State, as the crime is an offense against the sovereign. The prosecutor, however, lacks the personal knowledge of the facts material to the crime’s commission, having derived information only from investigation. Since a request for admission seeks the admission of the truth of facts or the genuineness of documents, it must be directed to a party with first-hand knowledge to avoid hearsay. The prosecutor, therefore, is not competent to answer.
Conversely, the accused is shielded by the constitutional right against self-incrimination. This right permits an accused to refuse not only to answer incriminatory questions but also to take the witness stand. Serving a request for admission on the accused would effectively compel them to be a witness against themselves, which is expressly prohibited. However, the ruling carves an exception for the civil aspect of the case. The private offended party has a direct interest in the civil liability arising from the crime. Consequently, a request for admission concerning matters relevant to the civil aspect may properly be served on the private offended party or their counsel, as they are the real party in interest for that component of the action.