TL;DR
The Supreme Court ruled that a lawyer can answer a request for admission on behalf of their client, interpreting “the party to whom the request is directed” in Rule 26 of the Rules of Court to include authorized legal counsel. This decision clarified that requiring only the party’s personal response would undermine agency principles and the attorney-client relationship. The Court also emphasized that requests for admission should introduce relevant evidentiary matters rather than simply reiterating existing allegations in the pleadings. This ensures the mode of discovery serves its purpose of expediting trials and reducing costs, preventing redundancy and delay.
Can Your Lawyer Answer for You? Unpacking the Rules on Requests for Admission
The tragic death of Dr. Hemedez following a strike dispersal operation at Nestle’s Cabuyao plant led to a legal battle involving multiple parties, including Nestle Philippines, its employees, and law enforcement. A crucial point of contention arose: Can a lawyer respond to a request for admission on behalf of their client? This question delves into the interpretation of procedural rules and the extent of an attorney’s authority in legal proceedings.
The case revolves around the interpretation of Rule 26, Section 2 of the Rules of Court, which states that “the party to whom the request is directed” must provide a sworn statement either admitting or denying the matters presented. The Hemedez spouses argued that this rule necessitates a personal response from the party, not their counsel, claiming that a lawyer’s answer would be based on hearsay. This argument challenges the established understanding of the attorney-client relationship and the scope of a lawyer’s authority in legal representation.
Building on this principle, the Supreme Court referenced Section 21 of Rule 138, highlighting that an attorney is presumed to be properly authorized to represent their client. Furthermore, Section 23 of Rule 138 provides that attorneys have the authority to bind their clients in any case by agreements made in writing related to the case and matters of ordinary judicial procedure. The Court stated:
Thus, when Rule 26 states that a party shall respond to the request for admission, it should not be restrictively construed to mean that a party may not engage the services of counsel to make the response in his behalf. Indeed, the theory of petitioner must not be taken seriously; otherwise, it will negate the principles on agency in the Civil Code, as well as Sec. 23, Rule 138, of the Rules of Court.
Moreover, the Court emphasized that requests for admission should not merely reiterate existing allegations in the pleadings. In Po v. Court of Appeals, it was held that a party should not be compelled to admit facts already admitted in their pleading. A request for admission should set forth relevant evidentiary matters to establish a party’s cause of action or defense. This approach contrasts with using requests for admission as a redundant tool, which would only delay the proceedings.
The Court also addressed the issue of proper service of the request for admission. Section 1 of Rule 26 requires that the request must be served directly upon the party requested. The Court found it unfair and unreasonable to expect parties to answer requests they did not personally receive. This underscores the importance of proper service to ensure that parties are duly notified and given the opportunity to respond.
Ultimately, the Supreme Court granted the petitions, setting aside the Court of Appeals’ decision and ordering the Regional Trial Court of Laguna to proceed with the resolution of the civil case. The Court’s ruling reinforced the role of legal counsel in representing their clients and clarified the scope of Rule 26, ensuring that the rule is applied in a manner that promotes justice and efficiency.
FAQs
| What was the key issue in this case? | The key issue was whether a lawyer could answer a request for admission on behalf of their client under Rule 26 of the Rules of Court. |
| What did the Supreme Court rule? | The Supreme Court ruled that a lawyer can answer a request for admission on behalf of their client, interpreting “the party” to include authorized legal counsel. |
| Why did the Court make this ruling? | The Court reasoned that restricting the response to only the party personally would undermine agency principles and the attorney-client relationship. |
| What is the purpose of a request for admission? | A request for admission aims to expedite trials and reduce costs by establishing facts that are not disputed and can be ascertained by reasonable inquiry. |
| Can a request for admission simply repeat allegations already in the pleadings? | No, a request for admission should set forth relevant evidentiary matters, not merely reiterate existing allegations. |
| Is it necessary to personally serve the request for admission to the party? | Yes, the request must be served directly upon the party to ensure they are duly notified and given the opportunity to respond. |
| What happens if a party fails to respond to a request for admission? | If a party fails to respond within the designated period, the matters in the request are deemed admitted. |
For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.
Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Rey Lañada vs. Court of Appeals and Nestle Philippines, Inc. vs. Court of Appeals, G.R. No. 102390, February 1, 2002
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