Case Digest: ROGER MANZANO v. LUZ DESPABILADERAS

ROGER MANZANO v. LUZ DESPABILADERAS

           Petitioner Roger Manzano (Manzano) filed an action for the enforcement of money debt with damages before the Regional Trial Court (RTC) of Iriga against Respondent Luz Despabiladeras (Despabiladeras) who received construction materials from the former on credit. During pre-trial, the parties agreed that Manzano shall submit an ”offer to stipulate” showing an itemized list of materials delivered to Despabiladeras together with the cost claimed by Manzano within 15 days. Despabiladeras shall state her objections if any or comment therein within the same period of time.

              Instead of submitting the same, Manzano filed a ”Request for Admission” asking Despabiladeras to admit the materials particularly described therein, that the value of the goods delivered amount to P314,610.50 and that only P130,000.00 has been paid. But Despabiladeras gave no response to the said request.

The RTC ruled against Despabiladeras while The Court of Appeals held in her favor setting aside the implied admission which served as the basis of the RTCes decision.

ISSUE:

Whether or not the unanswered request for admission has any legal consequences

HELD:

Rule 26 of the Rules of Court provides that at any time after issues have been joined, a party may serve upon any other party a written request for the admission by the latter of the genuineness of relevant documents described in and exhibited with the request or of the truth of any material and relevant matters of fact set forth in the request.

The above-quoted sections should not be disregarded as in fact the trial court did not, when it ordered Despabiladeras to file comment thereon, just because the parties mutually agreed that Manzano submit “an offer to stipulate.” For as stated earlier, the request for admission is a remedy afforded any party after the issues have been joined.

Despabiladeras having failed to discharge what is incumbent upon her under Rule 26, that is to deny under oath the facts bearing on the main issue contained in the “Request for Admission” she was deemed to have admitted that she received the construction materials, the cost of which was indicated in the request and was indebted to the petitioner in the amount stated therein.