6/6/25, 9:36 PM People vs.
Ang
Title
People vs. Ang
Case Decision Date
G.R. No. 231854 Oct 6, 2020
Respondents accused of malversation, falsification, and graft involving P4.8M fraud at
DBP-Lucena. SC ruled Rule 26 requests for admission inapplicable in criminal cases,
voiding RTC orders.
SC ruled that implied admissions from Requests for Admission are not applicable in
criminal cases.
Jur.ph - Case Digest (G.R. No. 231854)
Reasoning Model - Advanced
Facts:
Background of the Case
The case arose from criminal charges filed against respondents—including Leila L.
Ang, Rosalinda Driz, Joey Ang, Anson Ang, and Vladimir Nieto—for offenses such as
falsification of public documents, malversation of public funds under the Revised
Penal Code, and violation of the Anti-Graft and Corrupt Practices Act (RA 3019).
The underlying allegations involved fraudulent transactions at the Development
Bank of the Philippines (DBP) – notably, the unauthorized crediting of deposits to
accounts without actual cash deposits and the creation of fictitious journal entries
to conceal discrepancies in the Cash-in-Vault account of the DBP-Lucena City
Branch.
Lower Court Proceedings and Request for Admission
After the initial investigations and subsequent indictments, criminal information
was filed in November 2005 before the Regional Trial Court (RTC) of Lucena.
Leila Ang, then an accused and document analyst of DBP-Lucena, filed a Request for
Admission in Criminal Case No. 2005-1048. This request sought for the People (the
prosecuting entity) to admit various factual issues—many of which were framed
defensively to deny her participation or complicity in the alleged crimes.
The Office of the City Prosecutor initially handled the matter, and the RTC at Branch
53 denied the request, ordering its expunction from the records.
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Subsequent motions—including Leila Ang’s motion for partial reconsideration and a
motion to inhibit the presiding judge—resulted in the transfer of the cases to RTC
Branch 56 under Judge Dennis R. Pastrana.
Judge Pastrana, in a Joint Order dated February 12, 2015, ruled that because the
People failed to oppose or deny the Request for Admission within the prescribed 15-
day period, the facts stated therein were deemed impliedly admitted. He further
declared these de facto admissions as “judicial admissions” to be applied not only
in Criminal Case No. 2005-1048 but also by adoption in related consolidated cases
(Criminal Case Nos. 2005-1046 and 2005-1047).
Appellate and Certiorari Proceedings
The People challenged these judicial orders and the use of the Request for
Admission mechanism in criminal proceedings; they contended that such
admissions should be limited to the case in which they were made and not
extended by consolidation.
Through a petition for certiorari (initially under Rule 65), the People assailed the
RTC’s orders and, consequently, the decision of the Sandiganbayan (dated March 1,
2017, with a subsequent resolution on May 15, 2017) which dismissed their petition.
Among the issues raised, the People contended that a Request for Admission as
provided under Rule 26 of the Rules of Civil Procedure is improperly applied in
criminal cases. They also argued technical defects regarding the service of the
request and questioned the authority of the deputized counsel, Atty. Michael Vernon
De Gorio, to represent the People before the appellate court.
Issue:
Applicability of Requests for Admission in Criminal Proceedings
Whether a Request for Admission under Rule 26, a tool designed for civil discovery,
can be used in criminal cases without violating the constitutional rights of the
accused.
Whether the lower courts erred in treating the failure to deny the Request for
Admission as equivalent to a judicial admission that binds the parties across
consolidated criminal cases.
Authority of the Deputized Counsel
Whether Atty. De Gorio, acting as a special prosecutor under the
deputization/authorization provided by the Ombudsman's Office, had the proper
authority to file the petition for certiorari before the Sandiganbayan.
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Whether technical and procedural irregularities (such as the proper filing and the
signature on the certificate of non-forum shopping) warrant dismissal of the
petition.
Ruling:
The Supreme Court granted the petition for certiorari.
The Court reversed and set aside the Sandiganbayan’s Decision dated March 1, 2017
and the Resolution dated May 15, 2017 dismissing the petition.
The Court declared void the RTC’s Joint Orders (including those dated February 12,
2015, March 10, 2016, July 24, 2015, and September 5, 2016) which had treated the
alleged Request for Admission and its resulting implied admissions as judicial
admissions extending to all consolidated criminal cases.
On the Issue of Request for Admission
The Court held that a Request for Admission under Rule 26 of the Rules of Civil
Procedure is inapplicable in criminal proceedings.
It emphasized that compelling an accused to respond to such requests would
effectively require him to testify against himself, thereby infringing his
constitutional right against self-incrimination.
The mere consolidation of cases does not justify extending the effects of a request
designed for a civil context to criminal matters.
On the Authority of the Deputized Counsel
The Court found that Atty. Michael Vernon De Gorio acted within the scope of his
deputization to represent the People in pending criminal proceedings, including
filing the petition before the Sandiganbayan.
The Court held that the deputization remains valid so long as the trial court
proceedings have not concluded.
Ratio:
Incompatibility of Rule 26 with Criminal Proceedings
Rule 26 is tailored for civil cases where both parties have personal knowledge of the
facts and where discovery does not risk self-incrimination.
Applying this Rule in criminal cases would force an accused to potentially make
admissions or denials that could be self-incriminatory, violating the constitutional
right against self-incrimination.
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Unlike civil litigation, in criminal cases the party prosecuting (the People) is a
juridical entity represented by a public prosecutor who does not have the requisite
personal knowledge to satisfy the mechanism’s requirements.
Preclusion of Improper Consolidation
The Court reasoned that even if a request for admission could theoretically narrow
the factual issues in civil cases, its use in criminal cases risks prematurely closing
the issues by accepting as proven matters which the prosecution has yet to
establish beyond a reasonable doubt.
The consolidation of criminal cases does not justify forcing judicial admissions
across multiple, separate proceedings where each case must be decided on its own
merits.
Validity of Representational Authority
The authority granted to a deputized counsel is operative until the termination of
trial court proceedings.
Hence, the petition filed by Atty. De Gorio is valid, and its filing does not exceed the
limits of his prescribed deputization.
Doctrine:
Distinction Between Civil and Criminal Discovery
Discovery tools developed under the Rules of Civil Procedure—such as requests for
admission—are not automatically applicable to criminal cases because the nature,
objectives, and safeguards in criminal litigation are substantially different from
those in civil litigation.
The right against self-incrimination prohibits compelling a defendant to provide
evidentiary admissions that may be self-damaging.
Judicial Admissions and the Role of Pre-Trial Procedures
Judicial admissions in criminal cases should be expressly obtained and are subject
to safeguards during the trial, notably through the pre-trial process (e.g., stipulation
of facts under Rule 118).
The improper use of Rule 26 to effectuate judicial admissions in criminal litigation
may undermine the prosecution’s duty to prove guilt beyond reasonable doubt.
Void Judgments Resulting from Grave Abuse of Discretion
Orders rendered with grave abuse of discretion—such as the improper acceptance
of a Request for Admission in a criminal context—are void and constitute nullities.
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Such void orders do not have binding or enforceable impact on the merits of the
case.
Limits on the Extension of Consolidation Effects
The consolidation of closely related criminal cases does not grant permission for
inadmissible evidence or methods of discovery in one case to be automatically
applied to another.
Each criminal case must remain governed by the principles of due process and the
constitutional protection of the accused, thereby precluding the inappropriate
merging of evidentiary issues.
Authority and Representation by Deputized Counsel
A deputized counsel is empowered to represent the People in all pending
proceedings until the conclusion of the trial court’s process, ensuring continuity in
the prosecution even when cases are appealed.
This principle underscores that procedural challenges regarding representation
must be resolved in light of the continuing nature of criminal proceedings.
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