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REPUBLIC OF PHILIPPINES v. SANDIGANBAYAN

FACTS:

This case involves a civil case filed by the Presidential Commission on Good Government (PCGG) against defendants including Bienvenido R. Tantoco, Jr. and Dominador R. Santiago. The complaint sought reconveyance, reversion, accounting, restitution, and damages. Tantoco, Jr. and Santiago filed a motion to strike out certain portions of the complaint and requested a bill of particulars for other portions. The PCGG opposed this motion, and the defendants filed a reply to the opposition. The Sandiganbayan gave the PCGG 45 days to expand its complaint and make certain allegations more specific. Tantoco and Santiago then filed a motion for leave to file interrogatories seeking information on the PCGG commissioners who authorized their inclusion as defendants. The PCGG moved to strike out the motion and interrogatories. The PCGG eventually filed an expanded complaint, and Tantoco and Santiago reiterated their motion for a bill of particulars. The Sandiganbayan denied the motions. The defendants then filed an answer with compulsory counterclaim, and the PCGG presented a reply along with a motion to dismiss the counterclaim. The case was set for pre-trial, and Tantoco and Santiago filed interrogatories and a motion for production and inspection of documents. The Sandiganbayan admitted the amended interrogatories and granted the motion for production and inspection of documents. The PCGG filed a Motion for Reconsideration, but it was denied. The PCGG filed a petition for certiorari, claiming that the orders were rendered with grave abuse of discretion. The Court issued a temporary restraining order. The Solicitor General withdrew as counsel for the PCGG, and PCGG Commissioner Maximo A. Maceren took charge of the cases. The Court proceeded to decide the case, and the facts were not in dispute. The case involved the modes of discovery: interrogatories to parties and production and inspection of documents.

This case emphasizes the importance of presenting all material and relevant facts to the court in order to achieve a fair and just adjudication. Litigation should not be approached as a game of technicalities, but rather as a contest where each party lays before the court the facts in issue. The duty of laying the facts before the court is initially fulfilled through the pleadings filed by the parties, but only in a general way. Pleadings only contain "ultimate facts" and provide a basic outline of a party's claims or defenses. The law requires that pleadings must contain a plain, concise, and direct statement of the ultimate facts relied upon, excluding mere evidentiary facts. However, if the ultimate facts are alleged too generally or without sufficient definiteness to allow an adverse party to properly prepare a responsive pleading or for trial, the court may order a bill of particulars to obtain a more definite statement. It should be noted that a bill of particulars only serves to make the ultimate facts in a pleading more particular or definite and does not provide evidentiary details. The law allows parties to discover or inform themselves of all the relevant facts before trial through the use of the deposition-discovery mechanism provided in Rules 24 to 29 of the Rules of Court. This ensures that civil trials are not conducted in the dark and promotes efficient and effective adjudication.

ISSUES:

  1. Is it necessary for the ultimate facts in a pleading to be alleged with sufficient definiteness or particularity to enable the opposing party to prepare their responsive pleading or to prepare for trial?

  2. Is a bill of particulars limited to making more particular or definite the ultimate facts in a pleading and not to supply evidentiary matters?

  3. Whether the interrogatories served on the petitioner are defective and should not be answered.

  4. Whether the interrogatories deal with factual matters which will be part of the petitioner's proof upon trial.

  5. Whether the interrogatories would make PCGG Commissioners and officers witnesses, in contravention of Executive Order No. 14 and related issuances.

  6. Whether a party can call an adverse party as a witness and interrogate them.

  7. Whether the PCGG officers are required to answer interrogatories.

  8. Whether the PCGG is immune from counterclaims and being subjected to the rules of discovery.

  9. Whether the Sandiganbayan's Order for the production and inspection of specified documents and things allegedly in its possession is null and void.

  10. Whether the documents sought to be produced and inspected are confidential and should not be disclosed.

RULING:

  1. Yes, it is necessary for the ultimate facts in a pleading to be alleged with sufficient definiteness or particularity to enable the opposing party to prepare their responsive pleading or to prepare for trial. If this requirement is not observed, a bill of particulars seeking a more definite statement may be ordered by the court on motion of a party.

  2. Yes, a bill of particulars is limited to making more particular or definite the ultimate facts in a pleading and does not supply evidentiary matters.

  3. The objections to the interrogatories served on the petitioner cannot be sustained. The interrogatories are addressed to the PCGG as a juridical entity and can be answered by any officer competent to testify on its behalf. It is irrelevant that the interrogatories do not name specific individuals in the PCGG. The matters subject of the interrogatories are proper subject of discovery and the interrogatories themselves are sufficiently specific. The petitioner may object to specific items of the interrogatories on grounds of relevancy, privilege, bad faith, or oppression, but until such objection is presented and sustained, the obligation to answer remains.

  4. The fact that the interrogatories deal with factual matters that will be part of the petitioner's proof upon trial is not a ground for suppressing them. Discovery aims to ensure mutual knowledge of all relevant facts before trial. Either party may compel the other to disclose whatever facts they have in their possession. The stage at which disclosure of evidence is made is advanced from the time of trial to the period preceding it.

  5. The objection that the interrogatories would make PCGG Commissioners and officers witnesses, in contravention of Executive Order No. 14 and related issuances, is also unmeritorious. There is nothing wrong with a party making their adversary their witness. It is expressly allowed by the rules.

  6. Yes, a party can call an adverse party as a witness and interrogate them.

  7. Yes, the PCGG officers are required to answer interrogatories.

  8. No, the PCGG is not immune from counterclaims and being subjected to the rules of discovery.

  9. The Court finds that the Sandiganbayan's Order for the production and inspection of specified documents and things allegedly in its possession is valid and enforceable. The private respondents have the right to have copies of the documents in order to study them further or use them during the trial for any purpose allowed by law. The PCGG can allege and prove that said documents fall within some other privilege, constitutional or statutory.

  10. The Court finds that there is good cause for the production and inspection of the documents subject of the motion. Some of the documents are the basis of several material allegations of the amended complaint while others are to be used as evidence. The relevance of the documents is indisputable and their disclosure may not be opposed.

PRINCIPLES:

  • Pleadings must contain a plain, concise, and direct statement of the ultimate facts on which a party relies for their claim or defense.

  • A bill of particulars may be ordered by the court if the ultimate facts in a pleading are alleged too generally or not with sufficient definiteness or particularity.

  • The purpose of the deposition-discovery procedure is to enable parties to obtain the fullest possible knowledge of the issues and facts before civil trials and to prevent trials from being carried on in the dark.

  • The field of inquiry that may be covered by depositions or interrogatories is as broad as when the interrogated party is called as a witness to testify orally at trial.

  • The deposition-discovery procedure is to be accorded a broad and liberal treatment, and the time-honored cry of "fishing expedition" can no longer preclude a party from inquiring into the facts underlying their opponent's case.

  • Discovery by production or inspection of documents or things in accordance with the rules may be granted upon due application and showing of due cause.

  • The law imposes serious sanctions on a party who refuses to make discovery.

  • Limitations to discovery arise when it is conducted in bad faith or in a manner that annoys, embarrasses, or oppresses the person subject to the inquiry.

  • The liberty of a party to make discovery is unrestricted if the matters inquired into are relevant and not privileged, and the inquiry is made in good faith and within the bounds of the law.

  • When interrogatories are served on a juridical entity, the same shall be answered by any officer thereof competent to testify on its behalf.

  • Discovery aims to ensure mutual knowledge of all relevant facts before trial.

  • Either party may compel the other to disclose whatever facts they have in their possession.

  • The stage at which disclosure of evidence is made is advanced to the period preceding trial.

  • There is nothing wrong with a party making their adversary their witness.

  • Section 6, Rule 132 of the Rules of Court allows a party to call an adverse party as a witness and interrogate them.

  • Fishing expeditions are permitted through the modes of discovery.

  • The presence of parties other than those to the original action can be required for the granting of complete relief in the determination of a counterclaim or cross-claim.

  • The act of bringing suit entails a waiver of the exemption from giving evidence.

  • The State, in filing an action, divests itself of its sovereign character and sheds its immunity from suit.

  • Implied consent by the State to be sued is given when the State itself commences litigation or when it enters into a contract.

  • The defense of immunity from suit cannot be set up by the State against an action for payment by the owner in cases of expropriation without just compensation.

  • The PCGG is not immune from counterclaims and being subjected to the rules of discovery.

  • The rules of discovery allow parties to adequately prepare for pre-trial and trial.

  • The process of discovery through interrogatories and requests for admission is not complicated and is a simple matter of delivering a list of questions or a written communication to the party.

  • The sanctions for refusing to make discovery have already been mentioned.

  • The taking of depositions, either on oral examination or by written interrogatories, is not as complicated as commonly believed.