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Prof. Joselito Guianan Chan's The Labor Code of the Philippines, Annotated Labor Standards & Social Legislation Volume I of a 3-Volume Series 2019 Edition (3rd Revised Edition)
 

 
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UNITED STATES SUPREME COURT JURISPRUDENCE
 

 
PHILIPPINE SUPREME COURT JURISPRUDENCE
 

   
January-2000 Jurisprudence                 

  • G.R. No. 123951 January 10, 2000 - ROMEO RANOLA, ET AL. v. COURT OF APPEALS, ET AL.

  • A.M. No. P-00-1360 January 18, 2000 - ELISEO SOREÑO v. RHODERICK MAXINO, ET AL.

  • G.R. No. 114683 January 18, 2000 - JESUS C. OCAMPO v. OFFICE OF THE OMBUDSMAN, ET AL.

  • G.R. Nos. 118441-42 January 18, 2000 - ARMANDO JOSE, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 119594 January 18, 2000 - PEOPLE OF THE PHIL. v. BENZON ONG

  • G.R. No. 125994 January 18, 2000 - PEOPLE OF THE PHIL. v. BENJAMIN ANDALES

  • G.R. No. 127135 January 18, 2000 - EASTERN ASSURANCE AND SURETY CORP. (EASCO) v. COURT OF APPEALS, ET AL.

  • G.R. No. 129846 January 18, 2000 - REPUBLIC OF THE PHIL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 130944 January 18, 2000 - PEOPLE OF THE PHIL. v. VICENTE ALIB, ET AL.

  • G.R. No. 131675 January 18, 2000 - PEDRO C. LAMEYRA v. GEORGE S. PANGILINAN

  • G.R. No. 132378 January 18, 2000 - ROGELIO JUAN v. PEOPLE OF THE PHIL.

  • G.R. No. 132767 January 18, 2000 - PHIL. VETERANS BANK v. COURT OF APPEALS, ET AL.

  • G.R. No. 134854 January 18, 2000 - FELIZARDO S. OBANDO, ET AL. v. EDUARDO F. FIGUERAS, ET AL.

  • G.R. No. 139465 January 18, 2000 - SECRETARY OF JUSTICE v. RALPH C. LANTION, ET AL.

  • A.M. No. MTJ-00-1245 January 19, 2000 - ANTONIO YU-ASENSI v. FRANCISCO D. VILLANUEVA

  • A.M. No. MTJ-97-1129 January 19, 2000 - FLAVIANO B. CORTES v. FELINO BANGALAN

  • A.M. No. RTJ-99-1513 January 19, 2000 - ALFREDO B. ENOJAS v. EUSTAQUIO Z. GACOTT

  • G.R. No. 107320 January 19, 2000 - A’ PRIME SECURITY SERVICES v. NLRC, ET AL.

  • G.R. Nos. 113666-68 January 19, 2000 - GOLDEN DONUTS, INC. v. NLRC, ET AL.

  • G.R. No. 114761 January 19, 2000 - ALEMAR’S SIBAL & SONS v. NLRC, ET AL.

  • G.R. No. 119217 January 19, 2000 - PEOPLE OF THE PHIL. v. MIGUEL S. LUCBAN

  • G.R. No. 122104 January 19, 2000 - PEOPLE OF THE PHIL. v. PEPITO ORBITA, ET AL.

  • G.R. Nos. 122297-98 January 19, 2000 - CRESCENTE Y. LLORENTE v. SANDIGANBAYAN, ET AL.

  • G.R. No. 122739 January 19, 2000 - PEOPLE OF THE PHIL. v. JOSE M. PANTORILLA, ET AL.

  • G.R. No. 123655 January 19, 2000 - ANGEL BAUTISTA v. COURT OF APPEALS, ET AL.

  • G.R. No. 123183 January 19, 2000 - PEOPLE OF THE PHIL. v. RUBEN SISON

  • G.R. No. 126516 January 19, 2000 - PEOPLE OF THE PHIL. v. SHIRLEY ALAO

  • G.R. No. 127572 January 19, 2000 - PEOPLE OF THE PHIL. v. SALVADOR VILLAR

  • G.R. No. 129072 January 19, 2000 - PEOPLE OF THE PHIL. v. ANTONIO ABUBU

  • G.R. No. 130957 January 19, 2000 - VH MANUFACTURING v. NLRC, ET AL.

  • G.R. No. 132152 January 19, 2000 - PEOPLE OF THE PHIL. v. EUGENIO ADRALES, ET AL.

  • G.R. No. 132248 January 19, 2000 - ERLINDA C. PEFIANCO v. MARIA LUISA C. MORAL

  • G.R. No. 132657 January 19, 2000 - WILLIAM DIU, ET AL. v. DOMINADOR IBAJAN, ET AL.

  • G.R. Nos. 132779-82 January 19, 2000 - PEOPLE OF THE PHIL. v. DONATO BERNALDEZ

  • G.R. No. 134003 January 19, 2000 - PEOPLE OF THE PHIL. v. ALBERT NAGUM

  • G.R. No. 134329 January 19, 2000 - VERONA PADA-KILARIO, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 134535 January 19, 2000 - PEOPLE OF THE PHIL. v. ALEJANDRO MAGNO, ET AL.

  • G.R. No. 137560 January 19, 2000 - MARIA G. CRUZ, ET AL. v. COURT OF APPEALS, ET AL.

  • A.C. No. 4749 January 20, 2000 - SOLIMAN M. SANTOS, JR. v. FRANCISCO R. LLAMAS

  • Adm. Matter No. MTJ-00-1241 January 20, 2000 - NAPOLEON S. VALENZUELA v. REYNALDO B. BELLOSILLO

  • A.M. No. MTJ-00-1242 January 20, 2000 - DANIEL DUMO, ET AL. v. ROMEO V. PEREZ

  • A.M. No. RTJ-00-1522 January 20, 2000 - ROMULO SJ TOLENTINO v. POLICARPIO S. CAMANO

  • G.R. No. 76371 January 20, 2000 - MARIANO TURQUESA, ET AL. v. ROSARIO VALERA, ET AL.

  • G.R. No. 87134 January 20, 2000 - PHIL. REGISTERED ELECTRICAL PRACTITIONERS, ET AL. v. JULIO FRANCA, ET AL.

  • G.R. Nos. 100718-19 January 20, 2000 - PEOPLE OF THE PHIL. v. FREDDIE JUAN, ET AL.

  • G.R. No. 106282 January 20, 2000 - PEOPLE OF THE PHIL. v. QUINCIANO RENDOQUE, ET AL.

  • G.R. No. 108067 January 20, 2000 - CYANAMID PHIL., INC. v. COURT OF APPEALS, ET AL.

  • G.R. No. 109376 January 20, 2000 - PANFILO O. DOMINGO v. SANDIGANBAYAN, ET AL.

  • G.R. No. 110807 January 20, 2000 - PEOPLE OF THE PHIL. v. REYNALD T. NARVASA

  • G.R. No. 110929 January 20, 2000 - ABELARDO LOPEZ, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 119652 & A.M. No. P-00-1358 January 20, 2000 - VENTURA O. DUCAT v. COURT OF APPEALS, ET AL.

  • G.R. No. 123860 January 20, 2000 - PEOPLE OF THE PHIL. v. EDWIN NAAG, ET AL.

  • G.R. No. 125451 January 20, 2000 - MARCIANA MUÑOZ v. COURT OF APPEALS, ET AL.

  • G.R. No. 126151 January 20, 2000 - MANILA INTERNATIONAL AIRPORT AUTHORITY, ET AL. v. SERGIO D. MABUNAY, ET AL.

  • G.R. No. 128887 January 20, 2000 - PEOPLE OF THE PHILS. v. EDGARDO AQUINO

  • G.R. No. 130713 January 20, 2000 - PEOPLE OF THE PHIL. v. GABRIEL FLORES

  • G.R. No. 130986 January 20, 2000 - PEOPLE OF THE PHIL. v. VICTOR PAILANCO

  • G.R. No. 131512 January 20, 2000 - LAND TRANSPORTATION OFFICE [LTO] v. CITY OF BUTUAN

  • G.R. No. 132368 January 20, 2000 - PEOPLE OF THE PHIL. v. PACITO GARCES, JR.

  • G.R. No. 133775 January 20, 2000 - FIDEL DABUCO, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. Nos. 131894-98 January 20, 2000 - PEOPLE OF THE PHILS. v. JESUS DOCENA

  • G.R. No. 134167 January 20, 2000 - NASSER IMMAM v. COMELEC, ET AL.

  • G.R. No. 125965 January 21, 2000 - PEOPLE OF THE PHIL. v. PATRICIO GOZANO

  • G.R. No. 133477 January 21, 2000 - PEOPLE OF THE PHIL. v. BENJAMIN RAFALES

  • G.R. No. 135904 January 21, 2000 - PEOPLE OF THE PHIL. v. ALVIN TAN

  • G.R. Nos. 89591-96 January 24, 2000 - PEOPLE OF THE PHIL. v. BONIFACIO SANZ MACEDA

  • G.R. No. 100518 January 24, 2000 - ASSOCIATION OF TRADE UNIONS (ATU), ET AL. v. OSCAR N. ABELLA, ET AL.

  • G.R. No. 101932 January 24, 2000 - FRANCISCO H. ESCAÑO, JR., ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 111285 January 24, 2000 - PEOPLE OF THE PHIL. v. VICENTE VALLA

  • G.R. No. 116066 January 24, 2000 - NUEVA ECIJA I ELECTRIC COOPERATIVE, ET AL. v. NLRC, ET AL.

  • G.R. No. 124715 January 24, 2000 - RUFINA LUY LIM v. COURT OF APPEALS, ET AL.

  • G.R. No. 125031 January 24, 2000 - PERMEX INC., ET AL. v. NLRC, ET AL.

  • G.R. No. 129693 January 24, 2000 - PEOPLE OF THE PHIL. v. RUDY CORTES

  • A.M. No. RTJ-00-1525 January 25, 2000 - MARTIN D. PANTALEON v. TEOFILO L. GUADIZ, JR.

  • G.R. No. 80129 January 25, 2000 - GERARDO RUPA, SR. v. COURT OF APPEALS, ET AL

  • G.R. No. 102706 January 25, 2000 - PEOPLE OF THE PHIL. v. LEON LUMILAN, ET AL.

  • G.R. No. 107427 January 25, 2000 - JAMES R. BRACEWELL v. COURT OF APPEALS, ET AL.

  • G.R. No. 113518 January 25, 2000 - PEOPLE OF THE PHIL. v. ESTEBAN ARLEE

  • G.R. No. 113684 January 25, 2000 - PEOPLE OF THE PHIL. v. ARMANDO GALLARDO, ET AL.

  • G.R. No. 116332 January 25, 2000 - BAYNE ADJUSTERS AND SURVEYORS v. COURT OF APPEALS, ET AL.

  • G.R. No. 119595 January 25, 2000 - PEOPLE OF THE PHIL. v. JOVITO BARONA, ET AL.

  • G.R. No. 120267 January 25, 2000 - CLARA ESPIRITU BORLONGAN, ET AL. v. CONSUELO MADRIDEO, ET AL.

  • G.R. No. 121439 January 25, 2000 - AKLAN ELECTRIC COOPERATIVE INCORPORATED (AKELCO) v. NLRC, ET AL.

  • G.R. No. 129246 January 25, 2000 - GREENFIELD REALTY CORP., ET AL. v. LORETO CARDAMA, ET AL.

  • G.R. Nos. 131633-34 January 25, 2000 - PEOPLE OF THE PHIL. v. CRESENCIANO ENOLVA

  • G.R. No. 133132 January 25, 2000 - ALEXIS C. CANONIZADO, ET AL. v. ALEXANDER P. AGUIRRE, ET AL.

  • G.R. No. 135874 January 25, 2000 - SECURITY BANK CORPORATION v. COURT OF APPEALS, ET AL.

  • A.M. No. 99-12-192-MTC January 26, 2000 - HOLD DEPARTURE ORDER ISSUED BY ACTING JUDGE ANICETO L. MADRONIO

  • A.M. No. RTJ-00-1524 January 26, 2000 - LUCIA F. LAYOLA v. BASILIO R. GABO, JR.

  • G.R. No. 107395 January 26, 2000 - TOURIST DUTY FREE SHOPS v. SANDIGANBAYAN, ET AL.

  • G.R. No. 126115 January 26, 2000 - PEOPLE OF THE PHIL. v. ALFONSO BALGOS

  • G.R. No. 131374 January 26, 2000 - ABBOTT LABORATORIES PHIL. v. ABBOTT LABORATORIES EMPLOYEES UNION, ET AL.

  • G.R. No. 133842 January 26, 2000 - FEDERICO S. SANDOVAL v. COMELEC, ET AL.

  • G.R. No. 133969 January 26, 2000 - NEMESIO GARCIA v. NICOLAS JOMOUAD, ET AL.

  • G.R. Nos. 102961-62, 107625 & 108759 January 27, 2000 - JESUS P. LIAO v. COURT OF APPEALS, ET AL.

  • G.R. No. 117040 January 27, 2000 - RUBEN SERRANO v. NLRC, ET AL.

  • G.R. No. 130843 January 27, 2000 - PEOPLE OF THE PHIL. v. ZOILO BORROMEO

  • Adm. Case No. 1474 January 28, 2000 - CRISTINO G. CALUB v. ABRAHAM SULLER

  • A.M. No. MTJ-00-1246 January 28, 2000 - HEIRS OF JUAN and NATIVIDAD GERMINANDA v. RICARDO SALVANERA

  • A.M. No. MTJ-99-1211 January 28, 2000 - ZENAIDA S. BESO v. JUAN DAGUMAN

  • A.M. No. P-93-985 January 28, 2000 - MARTA BUCATCAT v. EDGAR BUCATCAT, ET AL.

  • G.R. No. 112177 January 28, 2000 - PEOPLE OF THE PHIL. v. TITO ZUELA, ET AL.

  • G.R. No. 112329 January 28, 2000 - VIRGINIA A. PEREZ v. COURT OF APPEALS, ET AL.

  • G.R. No. 115824 January 28, 2000 - RAFAEL M. ALUNAN III, ET AL. v. MAXIMIANO C. ASUNCION, ET AL.

  • G.R. No. 125279 January 28, 2000 - PEOPLE OF THE PHIL. v. JESUS TANAIL

  • G.R. No. 124129 January 28, 2000 - PEOPLE OF THE PHIL. v. DOMINGO BRIGILDO

  • G.R. Nos. 124384-86 January 28, 2000 - PEOPLE OF THE PHIL. v. ROMENCIANO "OMENG" RICAFRANCA, ET AL.

  • G.R. No. 125671 January 28, 2000 - CONDO SUITE CLUB TRAVEL v. NLRC, ET AL.

  • G.R. No. 125865 January 28, 2000 - JEFFREY LIANG (HUEFENG) v. PEOPLE OF THE PHIL.

  • G.R. No. 126802 January 28, 2000 - ROBERTO G. ALARCON v. COURT OF APPEALS, ET AL.

  • G.R. No. 127568 January 28, 2000 - PEOPLE OF THE PHIL. v. ROLANDO BACULE

  • G.R. Nos. 129756-58 January 28, 2000 - PEOPLE OF THE PHIL. v. JULIAN DEEN ESCAÑO, ET AL.

  • G.R. No. 131520 January 28, 2000 - ESTELITA AGUIRRE v. COURT OF APPEALS, ET AL.

  • G.R. No. 131778 January 28, 2000 - HERMAN TIU LAUREL v. PRESIDING JUDGE, ET AL.

  • G.R. No. 132138 January 28, 2000 - PEOPLE OF THE PHILS. v. ROMEO LLAMO

  • G.R. No. 133486 January 28, 2000 - ABS-CBN BROADCASTING CORP. v. COMELEC

  • G.R. No. 133987 January 28, 2000 - PEOPLE OF THE PHIL. v. JOHNNY BARTOLOME

  • G.R. No. 136805 January 28, 2000 - DIESEL CONSTRUCTION COMPANY INC. v. JOLLIBEE FOODS CORP.

  • G.R. No. 137537 January 28, 2000 - SMI DEVT. CORP. v. REPUBLIC OF THE PHIL.

  • G.R. No. 137718 January 28, 2000 - REYNALDO O. MALONZO, ET AL. v. RONALDO B. ZAMORA, ET AL.

  • G.R. No. 139545 January 28, 2000 - MAIMONA H. N. M. S. DIANGKA v. COMELEC, ET AL.

  • A.M. No. MTJ-99-1226 January 31, 2000 - GLORIA LUCAS v. AMELIA A. FABROS

  • G.R. Nos. 88521-22 & 89366-67 January 31, 2000 - HEIRS OF EULALIO RAGUA v. COURT OF APPEALS, ET AL.

  • G.R. No. 105827 January 31, 2000 - J.L. BERNARDO CONSTRUCTION v. COURT OF APPEALS, ET AL.

  • G.R. No. 112139 January 31, 2000 - LAPANDAY AGRICULTURAL DEVT. CORP. v. COURT OF APPEALS, ET AL.

  • G.R. No. 115045 January 31, 2000 - UNIVERSITY PHYSICIANS SERVICES v. COURT OF APPEALS, ET AL.

  • G.R. No. 116729 January 31, 2000 - PEOPLE OF THE PHIL. v. MARLON LERIO

  • G.R. No. 120706 January 31, 2000 - RODRIGO CONCEPCION v. COURT OF APPEALS, ET AL.

  • G.R. No. 123094 January 31, 2000 - PEOPLE OF THE PHIL. v. LUISITO PAGLINAWAN

  • G.R. No. 125440 January 31, 2000 - GENERAL BANK AND TRUST CO., ET AL. v. OMBUDSMAN, ET AL.

  • G.R. No. 127797 January 31, 2000 - ALEJANDRO MILLENA v. COURT OF APPEALS, ET AL.

  • G.R. No. 128536 January 31, 2000 - ROQUE G. GALANG v. COURT OF APPEALS, ET AL.

  • G.R. No. 128607 January 31, 2000 - ALFREDO MALLARI SR., ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 129071 January 31, 2000 - PEOPLE OF THE PHIL. v. ROBERTO MILLIAM, ET AL.

  • G.R. Nos. 129505 & 133359 January 31, 2000 - OCTAVIO S. MALOLES II v. PACITA DE LOS REYES PHILLIPS

  • G.R. No. 130104 January 31, 2000 - ELIZABETH SUBLAY v. NLRC, ET AL.

  • G.R. No. 130666 January 31, 2000 - PEOPLE OF THE PHIL. v. CASIMIRO JOSE

  • G.R. No. 134437 January 31, 2000 - NATIONAL STEEL CORP. v. COURT OF APPEALS, ET AL.

  • G.R. No. 139758 January 31, 2000 - LUCIEN TRAN VAN NGHIA v. RUFUS B. RODRIGUEZ, ET AL.

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    G.R. No. 135874   January 25, 2000 - SECURITY BANK CORPORATION v. COURT OF APPEALS, ET AL.

     
    PHILIPPINE SUPREME COURT DECISIONS

    THIRD DIVISION

    [G.R. No. 135874. January 25, 2000.]

    SECURITY BANK CORPORATION, Petitioner, v. COURT OF APPEALS, SPOUSES AGUSTIN P. UY and PACITA TANG * SIOC TEN, DOMINGO UY, and Hon. PRUDENCIO A. CASTILLO JR. in his capacity as presiding judge of the Quezon City RTC (Branch 220), Respondents.

    D E C I S I O N


    PANGANIBAN, J.:


    Litigation should not be carried on in the dark. Courts are given great latitude in enabling the parties to inform themselves of all relevant facts, including those known only to their adversaries. For this reason, the rules on discovery are accorded broad and liberal interpretation.chanrobles.com : red

    The Case


    Before us is a Petition for Review on Certiorari assailing the July 8, 1998 Decision of the Court of Appeals (CA), 1 which affirmed the trial court’s grant of the Motions, filed respectively by Domingo Uy and Spouses Agustin Uy and Pacita Tang Sioc Ten, for the production and inspection of several documents.

    Also assailed by petitioner is the October 7, 1998 CA Resolution, which denied petitioner’s Motion for Reconsideration. 2

    The Facts


    The facts are summarized by the Court of Appeals (CA) in this wise: 3

    "Petitioner Security Bank Corporation (SBC) is a domestic banking corporation duly organized and existing under Philippine laws. It is one of the defendants in Civil Case No. Q-97-30330 entitled [S]pouses Agustin P. Uy and Pacita Tang Sioc Ten versus Security Bank Corporation, Domingo P. Uy and the Ex-Officio City Sheriff of Quezon City, for injunction and damages with an application for the issuance of a temporary restraining order and preliminary injunction.

    "Plaintiffs Spouses Agustin P. Uy and Pacita Tang Sioc Ten sought to enjoin Security Bank Corporation (SBC for brevity) and the Ex-Officio Sheriff of Quezon City from proceeding with the extra-judicial foreclosure of a mortgage over a piece of property registered under the respondent spouses’ names located at Cubao, Quezon City and covered by TCT No. RI-8731 (281736).

    "On February 25, 1997, a temporary restraining order was issued by Hon. Pedro M. Areola of the Regional Trial Court of Quezon City (Branch 85) where the case was originally assigned. The temporary restraining order was lifted on April 8, 1997 when Judge Areola resolved to deny the spouses’ application for a preliminary injunction. This denial prompted the said plaintiffs to file a motion for the inhibition of Judge Areola from hearing the case, hence, the case was re-raffled to Branch 220 presided over by respondent judge, Hon. Prudencio Altre Castillo, Jr.

    "On April 7, 1997, SBC filed its answer with compulsory counterclaim and cross-claim while defendant Domingo P. Uy filed on April 18, 1997 his answer with compulsory counterclaim and cross-claim. SBC filed its answer to defendant Domingo Uy’s cross-claim on April 28, 1997.

    "Before filing his answer to defendant SBC’s cross-claim, defendant Domingo P. Uy filed an Omnibus Motion (Production of Documents and Suspension and/or Extension of Time to File Answer to Cross-Claim) on the ground that all documents, papers and instruments made and executed by SBC on the evaluation, processing and approval of the loans of Jackivi Trading Center, Inc., the real estate mortgages (REM) and the Special Power of Attorney (SPA) themselves must first be produced before he [could] prepare and file the answer to SBC’s cross-claim. SBC filed its opposition to the aforesaid motion of Domingo Uy. In return defendant Domingo Uy filed a motion to admit reply with the reply attached and on June 3, 1997 SBC filed its rejoinder.chanrobles.com : law library

    "Acting on defendant Uy’s Omnibus Motion (Production of Documents and Suspension and/or Extension of Time to File Answer to Cross-Claim) the trial court issued an Order on June 25, 1997 denying the motion.

    "On July 16, 1997, Domingo P. Uy moved for the reconsideration of denial by filing an Omnibus Motion (Motion for Reconsideration and/or Extension of Time to File Answer to Cross-Claim).

    "On the other hand, plaintiffs also filed their Motion (For Production, Inspection and Copying of Documents) praying for the issuance of an order directing SBC to produce and allow them to inspect and copy the original and additional mortgage contracts executed by Jackivi Trading Center, Inc. and/or Jose Tanyao. Defendant SBC opposed the motion on July 25, 1997 by filing its Consolidated Opposition to the spouses’ Motion for Production, Inspection and Copying of Documents and Urgent Motion for a temporary restraining order and a writ of preliminary injunction. Respondent spouses filed their reply to the aforementioned consolidated opposition of SBC.chanrobles.com.ph : red

    "On August 3, 1997, SBC filed its opposition to respondent Domingo Uy’s motion for reconsideration of the Order dated June 25, 1997.

    "On October 2, 1997, the trial court issued the first assailed Order, the dispositive portion of which states, thus:chanrob1es virtual 1aw library

    ‘WHEREFORE, premises considered, defendant Security Bank Corporation is hereby ordered to produce and permit defendant Domingo P. Uy to inspect, copy or photograph the documents, papers and instruments made and executed on the evaluation, processing and approval of the loans of Jackivi Trading Center, Inc., during usual business hours and day after at least three (3) days notice in advance by defendant Domingo P. Uy to defendant Security Bank Corporation. However, the filing of the answer to cross-claim need not await the production of the documents. Defendant Uy is given, for the last time, ten (10) days from receipt within which to file answer to the cross-claim of defendant Security Bank Corporation, stating only the ultimate facts without including evidentiary matters.

    ‘Defendant Security Bank Corporation is hereby ordered to produce and permit plaintiff[s] to inspect, copy or photograph the original and additional mortgage contracts executed by Jackivi Trading Center, Inc. and/or Mr. Jose Tanyao within which (sic) usual business hours and day after at least three (3) days notice in advance by plaintiff to defendant Security Bank Corporation.

    The application for issuance of temporary restraining order is hereby DENIED. In the meantime, set the case for hearing on the application for issuance of writ of preliminary injunction on October 31, 1997, at 8:30 o’clock in the morning.

    Furnish the parties and counsels with a copy of this Order.

    SO ORDERED.’chanrobles.com.ph : red

    "SBC filed a motion for partial reconsideration of the Order, claiming that said order [did] not explain the basis for requiring it to produce the requested documents, and that there was no good cause for their production, hence, it cannot be compelled to produce the same.

    "Acting on the aforesaid motion, respondent judge issued the second assailed Order on November 25, 1997 denying the Motion for Partial Reconsideration."cralaw virtua1aw library

    Ruling of the Court of Appeals


    Affirming the trial court, the Court of Appeals held: 4

    "It will be noted that the only condition imposed by the Rules is that the production of the documents must be for ‘good cause.’

    "Contrary to the allegation of petitioner that respondent Domingo Uy ha[s] not shown good cause for the production of such documents, said respondent has sufficiently shown the good cause on which his motion is anchored [—] that of being able to intelligently prepare his defenses against the cross-claim of petitioner SBC.

    "On the other hand, the motion for production filed by the respondents spouses Uy and Pacita Tang Sioc Ten is likewise for good cause, it being necessary for a full determination of the issues raised in Civil Case No. Q-97-30330.

    "‘Good cause’ does not relate to the substance in the document but to the reason for producing relevant or material matters therein; so that the enforcement of the rule entails exercise of sound discretion. The burden is on the moving party to demonstrate the need for the documents sought beyond the relevancy or materiality of the evidence therein."cralaw virtua1aw library

    Hence, this Petition. 5

    The Issue


    In its Memorandum, petitioner submits this lone issue for the consideration of the Court: 6

    "Whether or not the Honorable Court of Appeals committed grave abuse of discretion 7 when it sustained the Orders of the Respondent Regional Trial Court dated 02 October 1997 and 25 November 1997 which granted the respective Motions [For Production, Inspection and Copying of Documents] of Respondents Spouses Agustin P. Uy and Pacita Tang Sioc Ten and Domingo Uy."cralaw virtua1aw library

    In the main, the Court is being asked to determine whether the appellate court erred in affirming the grant of the two Motions for production and inspection of documents.

    The Court’s Ruling


    The Petition is bereft of merit.

    Main Issue: Grant of Motions for Production and Inspection of Documents

    Petitioner Security Bank Corporation (SBC) maintains that, in sustaining the grant of the Motions for production, inspection and copying of documents filed by private respondents, the CA grossly misconstrued and misapplied Section 1, Rule 27 of the Rules of Court. Petitioner stresses that the CA erred in focusing only on the requirement of "good cause" and in ignoring the prerequisite of relevancy.

    Moreover, petitioner contests the "good cause" invoked by the CA. Specifically, it contends that the "good cause," which Respondent Domingo Uy relied upon to be able to prepare an answer to the cross-claim against him, was negated by the rulings of both the trial court and the CA requiring him to file such answer without awaiting the production of the documents sought.

    We disagree with petitioner. Section 1, Rule 27 of the 1997 Rules of Court provides:chanroblesvirtuallawlibrary

    "SECTION 1. Motion for production or inspection; order. — Upon motion of any party showing good cause therefor, the court in which an action is pending may (a) order any party to produce and permit the inspection and copying or photographing, by or on behalf of the moving party, of any designated documents, papers, books, accounts, letters, photographs, objects or tangible things not privileged, which constitute or contain evidence material to any matter involved in the action and which are in his possession, custody or control; or (b) order any party to permit entry upon designated land or other property in his possession or control for the purpose of inspecting, measuring, surveying, or photographing the property or any designated relevant object or operation thereon. The order shall specify the time, place and manner of making the inspection and taking copies and photographs, and may prescribe such terms and conditions as are just."cralaw virtua1aw library

    In Republic v. Sandiganbayan, 8 the Court discussed exhaustively the significance of the various modes of discovery, an example of which is the aforecited provision. In sum, the Court held that the said Rule aims to enable the parties to inform themselves, even before the trial, of all the facts relevant to the action, including those known only to the other litigants. Through this procedure, "civil trials should not be carried on in the dark." We quote:jgc:chanrobles.com.ph

    ". . . Indeed, it is the purpose and policy of the law that the parties — before the trial if not indeed even before the pre-trial — should discover or inform themselves of all the facts relevant to the action, not only those known to them individually, but also those known to their adversaries; in other words, the desideratum is that civil trials should not be carried on in the dark; and the Rules of Court make this ideal possible through the deposition-discovery mechanism set forth in Rules 24 to 29. The experience in other jurisdictions has been that ample discovery before trial, under proper regulation, accomplishes one of the most necessary ends of modern procedure: it not only eliminates unessential issues from trials thereby shortening them considerably, but also requires parties to play the game with the cards on the table so that the possibility of fair settlement before trial is measurably increased. . . .’

    "As just intimated, the deposition-discovery procedure was designed to remedy the conceded inadequacy and cumbersomeness of the pre-trial functions of notice-giving, issue-formulation and fact revelation theretofore performed primarily by the pleadings.chanrobles.com : chanrobles.com.ph

    "The various modes or instruments of discovery are meant to serve (1) as a device, along with the pre-trial hearing under Rule 20, to narrow and clarify the basic issues between the parties, and (2) as a device for ascertaining the facts relative to those issues. The evident purpose is, to repeat, to enable the parties, consistent with recognized privileges, to obtain the fullest possible knowledge of the issues and facts before civil trials and thus prevent that said trials are carried on in the dark."cralaw virtua1aw library

    It is clear that courts are given wide latitude in granting motions for discovery in order to enable parties to prepare for trial or otherwise to settle the controversy prior thereto. Thus, in the same case, the Court further held:jgc:chanrobles.com.ph

    "What is chiefly contemplated is the discovery of every bit of information which may be useful in the preparation for trial, such as the identity and location of persons having knowledge of relevant facts; those relevant facts themselves; and the existence, description, nature, custody, condition, and location of any books, documents, or other tangible things. Hence, ‘the deposition-discovery rules are to be accorded a broad and liberal treatment. No longer can the time-honored cry of ‘fishing expedition’ serve to preclude a party from inquiring into the facts underlying his opponent’s case. Mutual knowledge of all the relevant facts gathered by both parties is essential to proper litigation. To that end, either party may compel the other to disgorge whatever facts he has in his possession. The deposition-discovery procedure simply advances the stage at which the disclosure can be compelled from the time of trial to the period preceding it, thus reducing the possibility, of surprise. . . .’" 9

    In the present case, the CA did not err in affirming the trial court ruling that there was "good cause" for the grant of the Motions for inspection of documents. The latter’s holding that the documents were not indispensable to the preparation of the answer of Uy to the cross-claim did not militate against respondents’ availment of this important mode of discovery. As he himself averred in his Motion, the subject documents were "material and important to the issues raised in the case in general, and as between defendant and defendant SBC in particular." 10

    Verily, the CA noted that the documents would enable Respondent Uy to "intelligently prepare his defenses against the cross-claim of petitioner SBC," 11 and not merely to formulate his answer. Likewise, we agree with the appellate court that the Motion of Spouses Agustin Uy and Pacita Tang Sioc Ten was for a good cause, because the said documents were "necessary for a full determination of the issues raised in Civil Case No. Q-97-30330." 12

    Indeed, litigation is essentially an abiding quest for truth undertaken not by the judge alone, but jointly with the parties. Litigants, therefore, must welcome every opportunity to achieve this goal; they must act in good faith to reveal documents, papers and other pieces of evidence material to the controversy. In Alonzo v. Villamor, 13 the Court ruled:chanrobles.com : red

    "A litigation is not a game of technicalities in which one, more deeply schooled and skilled in the subtle art of movement and position, entraps and destroys the other. It is, rather a contest in which each contending party fully and fairly lays before the court the facts in issue and then, brushing aside as wholly trivial and indecisive all imperfections of form and technicalities of procedure, asks that justice be done on the merits. Lawsuits, unlike duels, are not to be won by a rapier’s thrust. Technicality, when it deserts its proper office as an aid to justice and becomes its great hindrance and chief enemy, deserves scant consideration from courts. There should be no vested right in technicalities. . . .’

    Materiality of the Subject Documents

    Petitioner points out that a party may be compelled to produce or allow the inspection of documents if six procedural requisites are complied with, viz.:jgc:chanrobles.com.ph

    "(a) The party must file a motion for the production or inspection of documents or things, showing good cause therefor;

    (b) Notice of the motion must be served to all other parties of the case;

    (c) The motion must designate the documents, papers, books, accounts, letters, photographs, objects or tangible things which the party wishes to be produced and inspected;

    (d) Such documents, etc. are not privileged;

    (e) Such documents, etc. constitute or contain evidence material to any matter involved in the action; and

    (f) Such documents, etc. are in the possession, custody or control of the other party." 14

    Petitioner contends that Requisite "e" has not been satisfied, arguing that respondents have not shown the relevancy or materiality of the documents subject of the Motions. Specifically, it maintains that the documents sought by Spouses Uy and Tang Sioc Ten — "the original and additional mortgage contracts executed by Jackivi Trading Center, Inc. 15 and/or Mr. Jose Tanyao" 16 — were not relevant to Civil Case Q-97-30330, which was for the declaration of the nullity of the January 27, 1993 and August 16, 1995 Real Estate Mortgages between Jackivi and petitioner. The existence or the absence of other mortgages executed by Jackivi, petitioner insists, has absolutely no bearing on the said case, because it does not in any way determine the validity or the invalidity of the subject Real Estate Mortgages.

    Petitioner also argues that the documents sought by Respondent Domingo Uy — "all the documents, papers and instruments made and executed by [Petitioner] SBC in the evaluation, processing and approval of the loans to Jackivi . . ." 17 — were not relevant, because the trial court itself ruled that he could prepare his answer to the cross-claim without those documents.

    These arguments are not persuasive. Section 1 of Rule 27 clearly provides that the documents sought must be "material to any matter involved in the action." Respondents have shown that the subject documents are indeed material to the present action.chanrobles.com : virtual law library

    Indeed, the factual backdrop of the case strengthens respondent’s cause. The civil action instituted by the Spouses Uy sought the annulment of two deeds of Real Estate Mortgage between Jackivi and petitioner. They allegedly issued a Special Power of Attorney to Respondent Uy to mortgage their property only for their benefit, not for that of Jackivi. Because he mortgaged the property as security for Jackivi’s loan, they contend that he exceeded his authority and that the contracts of real estate mortgage were consequently invalid. Petitioner, on the other hand, filed a cross-claim against him, because it "relied on the representations and documents submitted by [the latter] that he was duly authorized to mortgage the subject property." 18

    In this light, the relevance of the documents sought by Respondent Domingo Uy is readily apparent. The papers executed by the petitioner bank in evaluating and processing the real estate mortgage are manifestly useful in his defense against its cross-claim. The trial court’s ruling that he could file his answer without examining those documents does not prove that they are immaterial to the present action. The CA has held that those documents would enable him to "intelligently prepare his defenses against the cross-claim of Petitioner SBC." chanrobles virtua| |aw |ibrary

    So also, the additional mortgage contracts executed by Jackivi are material to the present action. Because a witness of petitioner admitted in court that there was a third mortgage contract between Jackivi and the bank, fair play demands that herein respondents must be given the chance to examine such additional mortgage contracts. In so doing, they can determine why petitioner was going after their property which was invalidly mortgaged by Respondent Uy, while the properties of the actual borrower, Jackivi, have not been touched or foreclosed by the bank.

    Indeed, the rule is that courts, in passing upon a motion for discovery, should be liberal in determining whether the documents in question are relevant to the subject matter of the action. 19 To repeat, the rule on discovery "requires the parties to play the game with cards on the table so that the possibility of fair settlement before trial is measurably increased." 20

    All in all, petitioner failed to show any reversible error on the part of the Court of Appeals. The Motions of respondents were for a good cause, and the documents sought were material to the action pending before the trial court.chanrobles virtual lawlibrary

    WHEREFORE, the Petition is DENIED and the assailed Decision is AFFIRMED. Costs against petitioner.

    SO ORDERED.

    Melo, Vitug, Purisima and Gonzaga-Reyes, JJ., concur.

    Endnotes:



    * Sometimes spelled "Teng" or "Tong" in the records.

    1. Penned by J . Salome A. Montoya, division chairman; with the concurrence of JJ Conchita Carpio Morales and Bernardo P. Abesamis, members.

    2. Rollo, p. 41.

    3. CA Decision, pp. 1-4; rollo, pp. 32-35.

    4. CA Decision, pp. 6-7; rollo, pp. 37-38.

    5. The case was deemed submitted for resolution on September 10, 1999, upon this Court’s receipt of Domingo Uy’s Memorandum, which was signed by Atty. Amorsolo Camara. Filed earlier were the Memoranda of the petitioner and the other respondents, prepared respectively by Atty. Niel Anthony Veloso and by Attys. Marius Corpus and Ephraim Cortez.

    6. Petitioner’s Memorandum, p. 5; rollo, p. 347.

    7. Although petitioner imputes "grave abuse of discretion" on the part of the Court of Appeals, it must be noted that the present Petition was filed under Rule 45, not Rule 65.

    8. 204 SCRA 213, 222-223, November 21, 1991, per Narvasa, CJ.

    9. Ibid., p. 224. Emphasis added.

    10. Rollo, p. 93.

    11. CA Decision, p. 7; rollo, p. 38.

    12. Ibid.

    13. 16 Phil. 315, July 26, 1910, per Moreland, J . See also Lim Tong Lim v. Philippine Fishing Gear Industries, GR No. 136448, November 3, 1999.

    14. Francisco, The Revised Rules of Court in the Philippines, Vol. II, 1966 ed., p. 225.

    15. Hereafter referred to as "Jackivi."cralaw virtua1aw library

    16. Rollo, p. 125.

    17. Rollo, p. 94.

    18. Petitioner’s Answer, p. 5; rollo, p. 75.

    19. See Moran, Comments on the Rules of Court, Vol. II, 1996 ed., p. 115.

    20. Republic v. Sandiganbayan, supra.

    G.R. No. 135874   January 25, 2000 - SECURITY BANK CORPORATION v. COURT OF APPEALS, ET AL.


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