GR 231854 Perlas Bernabe (Digest)
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 a criminal prosecution for violation of the Anti-Graft and Corrupt Practices Act before the Sandiganbayan. Accused Leila L. Ang filed a Request for Admission under Rule 26 of the Rules of Civil Procedure, seeking admissions from the prosecution on numerous factual matters related to the elements of the crime and her alleged participation. The Sandiganbayan recognized the validity of this request and ordered the prosecution to respond. The prosecution filed a petition for certiorari, arguing that a request for admission is a mode of discovery applicable only in civil proceedings and is incompatible with criminal procedure.
ISSUE
Whether a Request for Admission under Rule 26 of the Rules of Civil Procedure can be applied suppletorily to criminal proceedings.
RULING
No. The Supreme Court En Banc, in the main Decision concurred with by Justice Perlas-Bernabe, ruled that a Request for Admission cannot be applied to criminal cases. Justice Perlas-Bernabe’s Concurring Opinion provides the legal logic. While the Rules of Civil Procedure may apply suppletorily to criminal proceedings in the absence of a governing rule, this suppletory application cannot contravene substantive principles inherent to criminal law. Procedural or adjective law, which is merely implementary, cannot amend substantive law.
The core substantive premises of a criminal prosecution render Rule 26 conceptually incompatible. First, it shifts the burden of proof. The prosecution bears the exclusive burden to prove guilt beyond reasonable doubt. A request for admission that targets the elements of the crime or the accused’s participation essentially forces the State to prove its case through admissions, undermining this foundational principle. Second, it violates the right against self-incrimination. While the rule is directed at the adverse party (the prosecution), the admissions sought can conclusively establish facts against the accused without affording them the right to cross-examine, as an admitted fact under Rule 26 is deemed conclusively established. This circumvents the accused’s rights to confrontation and to a public trial. The Revised Rules of Criminal Procedure contain built-in discovery procedures, and the deliberate absence of a counterpart to Rule 26 therein confirms its incompatibility. Therefore, the Sandiganbayan committed grave abuse of discretion in recognizing the Request for Admission. The petition was granted.