PBP vs CA

Facts:
- State Investment House, Inc. (SIHI) filed a complaint for a sum of money
against the Producers Bank of the Philippines (PBP) for a) unpaid interest and
b) amount of the principal sum.
- PBP presented evidence to prove that PBP failed to pay the said amounts.
SIHI interposed the defense of payment.
- On presentation of its rebuttal evidence (cf Rule 30.5), SIHI served written
interrogatories to PBP where it requested that the answers to its questions
within 15 days from receipt thereof.
- Upon receipt, PBP filed a motion to quash the written interrogatories on the
ground that were improper since trial was about to be terminated.
- The RTC denied the motion to quash on the ground that the written
interrogatories will help facilitate the early disposition of the case and will
assist the court in determining the truth, thus, the ends of justice will be
subserved.
- On certiorari, the CA affirmed the RTC citing Rule 24.1. It held that the Rules
do not provide any time frame in the filing of depositions and other modes of
discovery.
Issue: W/N the RTC erred in admitting the written interrogatories filed by SIHI at the
rebuttal stage of the proceedings? NO
Held:
-

The SC held that Rule 24.1 indeed does not provide for any time frame within
which modes of discovery can be utilized, other than by stating that the same
should be availed of with leave of court after jurisdiction has been obtained
over the defendant, or without such leave after an answer has been served.
o

The use of discovery is encouraged, for it operates with desirable flexibility

under the discretional control of the trial court, which enjoys considerable
leeway in matters pertaining to discovery.
In Republic vs. Sandiganbayan, the Court held that the depositiondiscovery rules are to be accorded a broad and liberal treatment as it
contemplates the discovery off every bit of information which may be
useful in the preparation for trial. This 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.
In this case, the questions propounded by SIHI in its written interrogatories
were meant to elicit information pertinent to the nature of the defense raised
by PBP. By allowing the written interrogatories, the trial court was in a better
position to examine the evidence already presented and to determine w/n the
information sought by SIHI would expedite the case.
Should PBP answer the written interrogatories, SIHIs presentation of rebuttal
evidence may be circumscribed, thereby expediting the disposition of the
case. PBP would also not be adversely affected as it still can present its own
rebuttal evidence after SIHI rests its case.