G.R. No. 213027 : January 18, 2017

FACTS: Present consolidated petitions emanated from Civil Case No. 0141, when Republic filed Motion for Partial Summary Judgment with respect to another property listed in the 1991 Petition. By way of that motion, the Republic asked the Sandiganbayan to render judgment declaring the pieces of jewelry, known as the Malacañang Collection and specifically mentioned under paragraph 9 (6) of the 1991 Petition, as ill-gotten; and to subsequently cause this collection of jewelry to be declared forfeited in favor of the Republic. To support the Motion, Republic cited May 2009 letter sent to the PCGG by Imelda Marcos, through counsel, demanding “the immediate return of all her pieces of jewelry (i) taken by PCGG from Malacañang Palace and (ii) those turned over to PCGG by the U.S. Government.” The Republic argued that the letter proved the claim of the Marcoses that they owned the Malacañang Collection, including the Hawaii Collection. It further argued that in the 1991 Petition, they were deemed to have admitted the allegations regarding the pieces of jewelry. The Republic said that the words or stock phrases they used in their Answer had been declared by this Court in the Swiss deposits case as a “negative pregnant” and, as such, amounted to an admission if not squarely denied. Republic also filed a Request for Admission, addressed to the Marcoses, the admission of certain facts under oath. Republic submitted a Supplement to Motion for Partial Summary Judgment, as it restated that the object of the motion covered only the Malacañang Collection. The Marcoses stated that the Request for Admission was inconsistent with the Motion for Partial Summary Judgment and the Supplement thereto and further reserved their right to present additional arguments or comments on the Motion and the Supplement. Sandiganbayan ruled in favor of the Republic.

ISSUE: Whether or not the Sandiganbayan correctly granted the Motion for Summary Judgment of the Republic? Yes.

HELD: YES. A request for admission can be the basis for the grant of summary judgment. The request can be the basis therefor when its subject is deemed to have been admitted by the party and is requested as a result of that party’s failure to respond to the court’s directive to state what specifically happened in the case. The resort to such a request as a mode of discovery rendered all the matters contained therein as matters that have been deemed admitted pursuant to Rule 26, Section 2 of the 1997 Rules of Civil Procedure. On the basis of respondent Imelda Marcos’s letter dated 25 May 2009; respondents’ Answer to the 1991 Petition, which was considered to be a “negative pregnant” in Republic v. Sandiganbayan; and respondents’ failure to timely respond to petitioner’s Request for Admission, the Sandiganbayan thus correctly granted the Motion for Summary Judgment of the Republic. The Marcoses filed numerous pleadings, but none of these was made in response to the Request for Admission as required by Rule 26, Section 2149 of the Rules of Court until the Sandiganbayan eventually issued the Partial Summary Judgment dated 13 January 2014 and the Resolution dated 11 June 2014. In this case, when the Sandiganbayan required the Marcoses to file and serve their sworn answer to the Request for Admission but none was made. Hence, the Motion for partial Summary judgment was proper.