### Facts:
This case revolves around the construction of a perimeter fence by Kenrick Development Corporation (respondent) around parcels of land behind the Civil Aviation Training Center, resulting in the dispossession of around 30,228 square meters of land from the Air Transportation Office (ATO). The respondent claimed ownership through TCT Nos. 135604, 135605, and 135606, supposedly originating from TCT No. 17508. However, upon verification by the Land Registration Authority (LRA), these titles were found dubious as the ascendant titles had no records, and the land was within Villamor Air Base.
The Office of the Solicitor General (OSG) filed a complaint on behalf of the Republic (as represented by the LRA) against the respondent and Alfonso Concepcion for the revocation, annulment, and cancellation of certificates of title. Procedurally, the case moved through various incidents including discovery, pre-trial motions, and motions related to defaults and dismissals.
An urgent motion to declare the respondent in default was filed by the Republic following revelations by Atty. Garlitos during a congressional hearing, admitting his non-signature on the respondent’s answer to the complaint, labeling the answer as a “mere scrap of paper”. The trial court granted the motion, leading to the ex parte presentation of the Republic’s evidence.
The respondent’s attempt at reconsideration was denied by the trial court, propelling the matter to the Court of Appeals via a petition for certiorari on the trial court’s decision. The appellate court, however, reversed the trial court’s ruling, focusing on the reliability of Atty. Garlitos’ statements and his subsequent actions which suggested a tacit ratification of the signing of the answer on his behalf.
### Issues:
1. Whether the Court of Appeals erred in reversing the order of default against the respondent for failing to file a valid answer.
2. The applicability of the doctrine of adoptive admission in circumstances where the counsel did not sign the pleading.
3. The requirement of a pleading being signed by the party or counsel and the consequent legality of a pleading signed by someone other than the counsel or party.
### Court’s Decision:
The Supreme Court granted the petition, reversing the decision of the Court of Appeals, and reinstating the trial court’s resolution declaring the respondent in default. The Court emphasized that a pleading must be signed by the party or the counsel to be considered valid. It held that the actions of Atty. Garlitos, including his later explanations and justifications, amounted to an adoptive admission of the unsigned answer, but this did not validate the fundamentally deficient pleading. The Court underscored the non-delegable nature of the duty to sign pleadings and the inappropriateness of allowing someone other than the party or their counsel to sign, marking the respondent’s answer as without legal effect.
### Doctrine:
– **Adoptive Admission**: A party may adopt or ratify another person’s statements by their words or conduct, treating such statements as admissible evidence against them.
– **Signing of Pleadings**: Only the signature of the party or their counsel validates a pleading, enforcing the principle that the preparation and signing of pleadings cannot be delegated to unqualified persons.
### Class Notes:
– **Pleadings must be signed by the party or counsel:** According to Section 3, Rule 7 of the Rules of Court, every pleading must be personally signed by the party or their legal counsel. An unsigned pleading has no legal effect.
– **Adoptive Admission Explained:** A party’s express or implied agreement to or adoption of another’s statement may constitute an adoptive admission, making such statements admissible against them.
– **Responsibility Towards Legal Work:** Legal work, such as the drafting and signing of pleadings, is exclusive to members of the legal profession, emphasizing the non-delegable nature of these responsibilities.
### Historical Background:
The case showcases the procedural complexities involved in contesting real property claims, especially against the backdrop of issues related to titling and registration in the Philippines. It underscores the judiciary’s role in upholding procedural standards and the ethical responsibilities of legal practitioners, highlighting the significance of due diligence and authenticity in legal documentation and representation.
Leave a Reply