G.R. No. L-57821. January 17, 1985.
SEGUNDINO TORIBIO, EUSEBIA TORIBIO, and the HEIRS OF OLEGARIO TORIBIO, represented by his widow, ADELA DE LOS REYES, petitioners, vs. THE HON. JUDGE ABDULWAHID A. BIDIN, in his capacity as Presiding Judge, Branch I, Court of First Instance, City of Zamboanga, DALMACIO RAMOS, and JUANITO CAMACHO, respondents.

FACTS

Petitioners, heirs of Justa Francisco, filed a complaint for recovery of hereditary rights over a parcel of land against private respondents Dalmacio Ramos and Juanito Camacho. Petitioners alleged their shares in the inheritance had never been sold or transferred. In their answer, respondents asserted petitioners had sold their shares to their brother Dionisio Toribio, who subsequently sold them to the respondents. To support this defense, respondents attached to their answer xerox copies of the deeds of sale and made them integral parts of their pleading.
During trial, when petitioner Eusebia Toribio was asked if she executed any sale of her share, respondents’ counsel objected, invoking Sections 7 and 8, Rule 8 of the Revised Rules of Court on actionable documents. The trial court sustained the objection, ruling that the deeds constituted the foundation of the defense and, not having been specifically denied under oath by petitioners, their genuineness and due execution were deemed admitted. Petitioners filed a motion for reconsideration, arguing the documents were merely evidentiary and not the basis of the defense, thus a simple specific denial sufficed. The motion was denied, prompting this petition.

ISSUE

Whether the deeds of sale attached to the respondents’ answer are actionable documents constituting the very foundation of their defense, thereby requiring a sworn specific denial from petitioners to contest their genuineness.

RULING

No. The Supreme Court reversed the trial court’s order. The legal logic centers on the proper application of Rule 8, Sections 7 and 8. While the rule mandates that when an action or defense is based upon a written instrument, its genuineness is deemed admitted unless specifically denied under oath, the circumstances of this case warrant a liberal interpretation to serve substantial justice.
First, the petitioners had already placed the genuineness of any alleged sales in issue through their verified complaint, wherein they swore under oath that they never sold their shares. This put respondents on adequate notice that they would need to prove the deeds during trial. Second, and decisively, not all petitioners were parties to the disputed deeds. The heirs of Olegario Toribio, represented by his widow, were not signatories to the instruments. Under the explicit exception in Section 8, the rule on deemed admissions “does not apply when the adverse party does not appear to be a party to the instrument.” Therefore, as to these heirs, respondents bore the burden of proving the deeds’ genuineness and due execution irrespective of any sworn denial.
The Court emphasized that procedural rules are tools to facilitate justice, not to deny it on technicalities. The objective is to provide parties the fullest opportunity to establish their case. Requiring a sworn denial under these specific facts, where the complaint was verified and non-parties are involved, would be overly rigid and could unjustly deprive petitioners of their right to fully contest their claim to an inheritance. The trial court was ordered to receive the petitioners’ evidence on the disputed documents.