Implied Admission: The Impact of Unanswered Requests in Philippine Litigation

The Rules of Court give litigants a powerful tool to narrow the issues in a case: the request for admission. A party who receives such a request and fails to respond within the prescribed period is deemed to have admitted the matters stated therein. This rule can be decisive, as shown in Almendras v. South Davao Development Corporation, Inc. (G.R. No. 198209, March 22, 2017), where the petitioner’s failure to answer a request for admission led to the dismissal of his complaint.

The Facts of the Case

The petitioner, Alexis C. Almendras, filed an Amended Complaint seeking to annul a Deed of Sale over a parcel of unregistered land in Davao del Sur. He claimed that he had owned and occupied the property since 1978 until he was forcibly dispossessed by respondent South Davao Development Corporation, Inc. (SODACO) in 1994. He alleged that his relative, Caridad Almendras, sold the property to Rolando Sanchez, whom he described as a "dummy" of SODACO.

During the proceedings, Sanchez filed a Request for Admission addressed to the petitioner. The request asked the petitioner to admit the genuineness of certain guardianship court orders, the authenticity of the Deed of Sale, and several factual matters, including that the petitioner did not oppose the inclusion of the property in guardianship proceedings or the authority granted to the judicial guardians to sell it.

The petitioner, however, failed to file a sworn statement denying these matters or explaining why he could not admit or deny them. Sanchez then filed a Motion for Summary Judgment, arguing that there was no genuine issue as to any material fact.

The Issue Before the Court

The central question was whether the petitioner’s failure to respond to the Request for Admission amounted to an implied admission of the matters stated therein, and whether such admission justified the dismissal of his complaint through summary judgment.

The Ruling: Failure to Respond Means Implied Admission

The Supreme Court denied the petition, affirming the lower court’s ruling. The Court emphasized that under Section 2, Rule 26 of the Rules of Court, a party who fails to file and serve a sworn response to a request for admission within the reglementary period is deemed to have admitted the matters requested.

Because the petitioner did not file any response, the RTC correctly concluded that he was deemed to have admitted the facts stated in the request. These admissions included the fact that the property had been validly sold to Sanchez. With these facts admitted, the complaint no longer had any basis, and summary judgment was proper.

The Procedural Lesson: Rule 45 Is Not for Factual Disputes

Beyond the substantive rule on implied admission, the case also illustrates a critical procedural point. The petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, but he raised issues that were essentially factual in nature—such as whether he was properly served with the Request for Admission.

The Court reiterated that a petition for review under Rule 45 is limited to questions of law. It cannot be used to correct alleged errors of fact or to question the trial court's findings on service of pleadings. The Court also noted that the petitioner should have first appealed to the Court of Appeals rather than going directly to the Supreme Court, which violated the doctrine of hierarchy of courts.

Practical Takeaways

• Respond to requests for admission promptly. A failure to respond within the reglementary period results in implied admission of the matters stated, which can be fatal to a case.
• Use sworn responses. A party who wishes to deny the matters requested must do so under oath, or state in detail why he cannot admit or deny them.
• Summary judgment can follow implied admissions. If the admitted facts leave no genuine issue for trial, the court may render summary judgment without a full trial.
• Choose the correct mode of appeal. A petition for review under Rule 45 is limited to questions of law. Factual issues must be raised through an ordinary appeal to the Court of Appeals.
• Respect the hierarchy of courts. Direct resort to the Supreme Court without first seeking relief from the appropriate lower court may result in the dismissal of the petition.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.