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G.R. No. 231854. October 06, 2020 (Case Brief _ Digest)

The Supreme Court ruled in the case of People of the Philippines vs. Leila L. Ang that Requests for Admission under Rule 26 of the Rules of Civil Procedure do not apply to criminal proceedings, nullifying prior judicial admissions made by the RTC. The Court found that the RTC committed grave abuse of discretion in handling the Request for Admission and that the Sandiganbayan erred in dismissing the People's petition. This case emphasizes the distinction between civil and criminal procedures and the importance of protecting the accused's rights in criminal cases.

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18 views

G.R. No. 231854. October 06, 2020 (Case Brief _ Digest)

The Supreme Court ruled in the case of People of the Philippines vs. Leila L. Ang that Requests for Admission under Rule 26 of the Rules of Civil Procedure do not apply to criminal proceedings, nullifying prior judicial admissions made by the RTC. The Court found that the RTC committed grave abuse of discretion in handling the Request for Admission and that the Sandiganbayan erred in dismissing the People's petition. This case emphasizes the distinction between civil and criminal procedures and the importance of protecting the accused's rights in criminal cases.

Uploaded by

Thea Manzan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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G.R. No. 231854.

October 06, 2020 (Case Brief / Digest)

Title: People of the Philippines vs. Leila L. Ang, et al.

Facts:
On April 4, 2005, the Deputy Ombudsman for Luzon found probable cause to indict Leila L.
Ang and others for Falsification of Public Documents, Malversation of Public Funds, and
Violation of the Anti-Graft and Corrupt Practices Act. These offenses were allegedly
committed through fraudulent transactions involving cash deposits and the creation of a
fictitious journal entry in the Bank’s records. Informations were filed before the Regional
Trial Court (RTC) of Lucena, Branch 53.

Leila Ang, a Document Analyst at the Development Bank of the Philippines (DBP)-Lucena
Branch, along with the others, allegedly defrauded DBP of P4,840,884.00. The case
underwent several procedural steps including the filing of a Request for Admission by Leila
Ang, which the prosecuting office moved to expunge. This request for admission was initially
denied and expunged by the RTC but was later granted upon reconsideration by Judge
Pastrana in a different branch after the inhibition of Judge Obnamia. The facts stated in the
Request for Admission were deemed impliedly admitted for failing to be timely denied by the
prosecution.

The People’s subsequent motion for clarification was denied for being filed out of time, and
the facts stated in Ang’s Request for Admission were upheld as judicial admissions. These
implied admissions were adopted in related criminal cases as well. The People’s motion for
reconsideration of these rulings was denied by the RTC.

The People then filed a Petition for Certiorari under Rule 65 before the Sandiganbayan,
which was dismissed. The resolution argued that the RTC did not commit grave abuse of
discretion and that the implied admissions had procedurally become judicial admissions. The
People’s motion for reconsideration with the Sandiganbayan was also denied.

Issues:
1. Whether Requests for Admission under Rule 26 of the Rules of Court apply in criminal
proceedings.
2. Whether the RTC committed grave abuse of discretion in handling the Request for
Admission filed by Leila Ang.
3. Whether the Sandiganbayan erred in dismissing the People’s Petition for Certiorari.

Court’s Decision:
The Supreme Court granted the People’s petition, reversing and setting aside the

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G.R. No. 231854. October 06, 2020 (Case Brief / Digest)

Sandiganbayan’s decision. The Court ruled that:


1. Requests for Admission under Rule 26 of the Rules of Civil Procedure do not apply to
criminal proceedings, thereby nullifying the basis of the admissions made in the RTC.
2. The RTC committed grave abuse of discretion in its handling of the Request for Admission
and in upholding these as judicial admissions.
3. The Sandiganbayan’s dismissal of the People’s petition was in error, as it failed to properly
appreciate the applicability and consequences of Requests for Admission in criminal cases.
4. The People’s implied admissions obtained under Rule 26 in one case should not extend
their effect to other cases through consolidation.

Doctrine:
The doctrine established in this case emphasizes that Requests for Admission under Rule 26
of the Rules of Civil Procedure do not apply to criminal proceedings. Judicial admissions in
criminal cases must be based on voluntary and direct admissions by the parties or their
authorized representatives, not implied through procedural mechanisms intended for civil
disputes.

Class Notes:
– Discovery mechanisms in civil cases, such as Requests for Admission, cannot be directly
applied to criminal proceedings due to differences in procedural requirements and the
protection of the accused’s constitutional rights.
– The right against self-incrimination prohibits compelling an accused in a criminal case to
make admissions against themselves, differing fundamentally from civil case procedures.
– Procedural missteps and the misuse of civil discovery mechanisms in criminal cases can
result in grave abuse of discretion by the trial court.
– Consolidation of criminal cases for trial does not automatically allow for the transfer or
application of judicial admissions from one case to affect others.

Historical Background:
The case underscores the judiciary’s evolving approach to applying procedural rules across
different types of proceedings. It highlights the essential distinctions between civil and
criminal litigation, particularly concerning pre-trial discovery mechanisms and the rights of
the accused. The decision reaffirms the primacy of the accused’s constitutional protections in
the criminal justice system and clarifies the limitations on the use of civil procedure tools in
criminal cases.

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