FACTS:

The case involves an incident that occurred during a strike organized by the Union of Filipro Employees (UFE) against Nestle Philippines, Inc. (Nestle). To enforce a temporary restraining order (TRO) issued by the National Labor Relations Commission (NLRC), Nestle sought assistance from the Philippine Constabulary (PC) and the Cabuyao police, as well as the fire brigade of Cabuyao. Nestle also hired trucks from the Alimagno brothers to transfer its products. During the strike, a panel was formed to discuss the trucks and the presence of non-striking workers. However, in apparent bad faith, a member of Nestle signaled the PC to disperse the strikers at the barricades in front of the plant gate, causing injuries and arrests. As one of the trucks was leaving the compound, it collided with a car driven by Dr. Vied Vemir Garcia Hemedez, resulting in his death. The counsel of Nestle filed a request for admission under Rule 26 of the Rules of Court, but the opposing party's counsel objected, claiming that only the party to whom the request is addressed should answer.

In this case, the plaintiffs, spouses Rogelio and Eliza Hemedez, filed a civil case against Nestle, Jesus Alimagno, Francis Santos, Pacifico Galasao, and PC/Capt. Rey Lañada. The plaintiffs sought indemnity for the death of their son, Dr. Hemedez, as well as compensation for loss of earnings, compensation for the destruction of Dr. Hemedez's car, and damages.

Nestle and Santos denied liability for Dr. Hemedez's death and argued that Belltown Transport Services, Inc., an independent contractor, assumed liability for any injuries or damages that would arise from their agreement with Nestle. They claimed that the accident occurred during an illegal strike and that the strikers' violent assault on the truck was the proximate cause of Dr. Hemedez's death. They also argued that the complaint should be dismissed for failure to implead UFE, its officers, and striking members as indispensable parties. They set up a cross-claim against Galasao and a counterclaim for attorney's fees.

Captain Lañada, on the other hand, dismissed the claims against him and asserted that the incident was caused by the unruly mob's attack on the trucks, which resulted in a traffic jam. He argued that he and his men tried to save all casualties, including Dr. Hemedez, but the plaintiffs misinterpreted his actions as refusal. He filed a counterclaim for moral damages and attorney's fees.

The plaintiffs served the defendants a request for admission of the facts set forth in their complaint and the genuineness of the accompanying documents. The defendants filed their answers to the request for admission through their respective counsel. The plaintiffs then sought to strike out the defendants' answers, arguing that the parties themselves, not their counsel, should personally answer the request for admission.

The trial court denied the plaintiffs' motion, stating that the defendants' answers, filed through their counsel, were in accordance with the rules. The court held that the grounds raised by the plaintiffs' counsel were more formal than substantial.

ISSUES:

1. May the counsel of a party answer a written request for admission directed to the party under Section 1, Rule 26 of the Rules of Court?

2. Are the answers provided by counsel on behalf of the defendants considered specific denials in accordance with the rules?

3. Was the motion for reconsideration of the order striking out the defendants’ answers timely filed?

RULING:

1. Yes, the counsel of a party may answer a written request for admission on behalf of the party under Section 1, Rule 26 of the Rules of Court. The Supreme Court found that the language in Rule 26 did not need to be restrictively construed to mean that a party may not engage the services of counsel to respond on their behalf.

2. The issue of whether the answers filed by the counsel were specific denials was determined to be moot because the written requests for admission concerned ultimate facts previously dealt with in the defendants' pleadings, rendering the requests redundant and unnecessary.

3. The motion for reconsideration was deemed timely filed since the questioned order was interlocutory and not a final order that would dispose of the case's merits.

PRINCIPLES:

1. Representation by Counsel: Under the Rules of Court and Civil Code, an attorney may act on behalf of a client, including responding to requests for admission.

2. Redundancy in Requests for Admission: Requests for admission should not merely restate matters already addressed in pleadings and should serve to establish evidentiary facts. Redundant requests that only delay proceedings are discouraged.

3. Timeliness of Motions: Interlocutory orders, which do not dispose of the case's merits, are not subjected to the same 15-day reglementary period as final orders, making motions for reconsideration of such orders timely if filed beyond the 15-day period.