REMEDIAL LAW REVIEW CASE DIGEST

TOPIC Admission of Facts

CASE TITLE ALLIED AGRI-BUSINESS DEVELOPMENT CO., INC vs.CA
GR NO. G.R. No. 118438 DATE: December 4, 1998
DOCTRINE
The purpose of the rule governing requests for admission of facts and genuineness of documents is 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.
FACTS
A complaint was filed by respondent Cherry Valley for collection of sum of money against the petitioner Allied Agri-
Business for its failure to pay for the value of orders made and received by the latter. Cherry Valley served a Request
for Admission of Facts to Agri-Business. The latter failed to submit a sworn answer to the request for admission within
the allowed period. Thus, summary judgment ensued. Agri-Business alleged that Cherry Valley had the burden to prove
through its own witness during the trial the matters for which admissions were requested, and subsequently questioned
the summary judgment.
ISSUE
Whether or not respondent’s failure to answer the Request for Admission shall mean admission of the mailers stated in
the request which can be the basis for summary judgment?
HELD
YES. Petitioner cannot also successfully argue that its failure to answer the request for admission did not result in its
admission of the matters stated in the request.

The purpose of the rule governing requests for admission of facts and genuineness of documents is 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.

The records show that although petitioner filed with the trial court its comments and objections to the request for
admission served on it by private respondent, the trial court disregarded the objections and directed petitioner after
denying its motion for reconsideration, to... answer the request within five (5) days from receipt of the directive;
otherwise, the matters of which the admission was requested would be deemed admitted. Petitioner failed to submit the
required answer within the period. The matter set forth in the request were therefore deemed admitted by petitioner.
The burden of affirmative action is on the party upon whom notice is served to avoid the admission rather than upon the
party seeking the admission. Hence, when Agri-Business failed to reply to a request to admit, it may not argue that the
adverse, party has the burden of proving the facts sought to be admitted. Agri-Business’ silence is an admission of the
facts stated in the request. This now becomes the basis of a summary judgment.

NOTES

4C (2020 – 2021)