Lanada v CA

February 1, 2002 / De Leon, Jr., J.

Facts
The Union of Filipro Employees (UFE) declared a strike on account of alleged unfair
labor practices committed by Nestle Philippines, Inc. (Nestle) and put up a picket line
in front of the companys Cabuyao, Laguna factory.
NLRC issued a TRO enjoining the UFE to desist from blocking, barricading and
obstructing the points of ingress and egress from Nestles Cabuyao plant.
To enforce the TRO, Nestle sought the assistance of the Philippine Constabulary and
the fire brigade of Cabuyao.
Seeking to transfer its products from the Cabuyao factory to its warehouse in Taguig
during the strike, Nestle hired 6 cargo trucks from brothers Constancio and Jesus
Alimagno.
Alexander Asinas of the UFE and Francis Santos of Nestle agreed to constitute a
panel to discuss said transfer of products, as the matter was not overed by the TRO.
However, in bad faith, Santos instead ordered the PC to disperse the strikers at the
barricades in front of the plant gate so that the trucks can get out of the plant.
The PC and the fire brigade began hitting the strikers with truncheons and water
cannons.
With gate cleared, the cargo trucks began leaving the compound.
Meanwhile, Dr. Vied Vemir Garcia Hemedez was on his way home from his masteral
class at the UP College of Public Health.
He arrived at the Nestle factory while the dispersal was ongoing so he stopped his car.
At that time, the one of the cargo trucks, driven by Pacifico Galasao, was leaving the
Nestle compound at full speed.
To avoid stones being thrown at his direction, the truck driver drove in a crouching
position. However, he lost control of the truck and bumped the car of Dr. Hemedez.
Pinned down by his overturned car, Dr. Hemedez asked someone to inform his
parents and pleaded for help from the people.
While extricating Dr. Hemedez from the overturned car, his mother and brothers
repeatedly asked the help of PC soldiers, specifically to unload the cargo truck to
speed up the rescue, but said soldiers refused, saying that the truck might get looted if
they did so.
Dr. Hemedez was pulled out from under his car 2 hours later by his family members
and was rushed to the hospital, where he died shortly after arrival.
Spouses Rogelio and Eliza Hemedez, parents of Dr. Hemedez, sued Nestle, Jesus
Alimagno, Francis Santos, Pacifico Galasao, and PC/Capt. Rey Laada for damages.
After defendants filed their answers to the complaint, the Hemedez spouses served
the defendants a request for admission of the truth of the facts set forth in their
complaint and the genuineness of each of the documents appended thereto.
Through their respective counsel, defendants filed their verified answer to the request
for admission.

The Hemedez spouses moved to strike out said answers and to declare the matters
sought to be admitted as impliedly admitted, contending that defendants themselves
and not their counsel should personally answer the request for admission.
TC denied the spouses motion as well as the MR.
On certiorari in the SC, the matter was referred to the CA.
CA granted the motions to strike out the answers subject of the requests for admission
and declared each of the matters requested to be impliedly admitted. It also remanded
the case to the court a quo for proper proceedings.

Issue/Ratio:
1. Should a person to whom a request for admission is addressed personally answer
the request? NO.
PSFC Financial Corp. V CA: Section 23 of Rule 138 provides that (a)ttorneys have
authority to bind their clients in any case by any agreement in relation thereto made in
writing, and in taking appeals, and in all matters of ordinary judicial procedure x x x .
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.
In the case at bar, there is no showing that petitioners did not authorize their respective
counsels to file in their behalf their respective answers to the Hemedez spouses written
request for admission. As this Court has said, there is no reason to strictly construe the
phrase the party to whom the request is directed to refer solely or personally to
the petitioners themselves.
Moreover, the subject matters of the request for admission are the same as the ultimate
facts alleged in the complaint to which petitioners have already filed their respective
answers.
Po v. CA: A request for admission is not intended to merely reproduce or reiterate the
allegations of the requesting partys pleading but should set forth relevant evidentiary
matters of fact, or documents described in and exhibited with the request, whose purpose
is to establish said partys cause of action or defense.
Concrete Aggregates Corporation v. Court of Appeals: The rule on admission as a mode
of discovery is intended to expedite trial and to relieve parties of the costs of proving
facts which will not be disputed on trial and the truth of which can be ascertained by
reasonable inquiry.