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

Respondents, officers of DBP-Lucena and owners of certain business entities, were charged with Malversation, Falsification, and violation of the Anti-Graft and Corrupt Practices Act for allegedly defrauding the bank. During the proceedings before the Regional Trial Court (RTC), respondent Leila Ang filed a “Request for Admission” addressed to the “Plaintiff” concerning one of the cases. The Office of the City Prosecutor (OCP) of Lucena filed a motion to expunge it, which the RTC initially granted. Upon reconsideration before a different judge, the RTC reversed itself, ruling that the prosecution’s failure to respond within 15 days resulted in implied admissions under Rule 26 of the Rules of Court. The RTC later characterized these implied admissions as “judicial admissions” under Rule 129.
The prosecution, through a newly deputized special prosecutor, subsequently filed its own Requests for Admission upon the respondents and moved to consolidate the cases. The RTC denied the prosecution’s requests, holding that the prior judicial admissions by the People could no longer be contradicted. It then granted the respondents’ demurrers to evidence and dismissed all criminal cases. The Sandiganbayan dismissed the People’s petition for certiorari, prompting the instant appeal.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in affirming the RTC’s orders which: (1) deemed the prosecution to have made judicial admissions based on its failure to respond to a Request for Admission; and (2) consequently dismissed the criminal cases via demurrer to evidence.

RULING

Yes, the Sandiganbayan committed grave abuse of discretion. The Supreme Court reversed and remanded the cases for further proceedings. The core legal error was the RTC’s conversion of implied admissions from a request for admission into conclusive judicial admissions binding against the People in a criminal prosecution.
The Court clarified that a “Request for Admission” under Rule 26 is a mode of discovery, not a pleading. Its purpose is to simplify trials by identifying uncontroverted matters, but admissions obtained thereunder are not automatically elevated to the status of judicial admissions under Rule 129, which are formal, deliberate concessions made in pleadings or during trial that are binding and cannot be contradicted. The prosecution’s failure to respond to the request within the period resulted only in “implied admissions” for the purpose of that specific discovery procedure. These are not judicial admissions that conclusively bind the State, especially on matters constituting the very elements of the crimes charged. The RTC’s ruling effectively allowed a procedural discovery mechanism to foreclose the prosecution’s ability to present its case and prove the crimes, which is a violation of due process and the State’s duty to prosecute crimes. The grant of the demurrer to evidence based on these erroneous admissions was thus invalid.