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SECURITY BANK CORPORATION VS. COURT OF APPEALS Panganiban, J. | January 25, 2000 FACTS: - Security Bank Corporation (SBC) is one of the defendants in a Civil Case for injunction and damages. - The Sps. Uy sought to enjoin SBC from proceeding with the extrajudicial foreclosure of a mortgage over a piece of land. - When this was denied, the Sps. Uy filed a motion to inhibit the judge which resulted in the re-raffling of the case. - SBC filed its answer with counterclaim and cross-claim, while Uy filed his answer also with counterclaim and cross-claim. - Uy filed an Omnibus Motion on the ground that all documents, papers and instruments must be first produced before they could prepare and file their answers to SBC. - Acting on said motion, the TC granted such and ordered SBC to produce all its documents pertaining to the mortgage. - CA: affirmed the TC ISSUE: - WON the CA erred in affirming the grant by the lower court of the motion for the production and inspection of documents. HELD: - NO. RATIO: - Section 1, Rule 27 of the Rules of Court allows the parties to, upon a showing of good cause, file with the court to: o Order any party ot produce and produce the inspection and copying of paper, books and accounts or any matter involved in the action. o Order any party to permit entry upon land or property in his possession for the purpose of inspecting the same. - In Republic vs. Sandiganbayan o The court held that the said Rule aims to enable the parties to inform themselves, even before 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. o The deposition-discovery procedure was designated to remedy the conceded inadequacy and cumbersomeness of the pre-trial functions of notice-giving, issue-formulation and fact revelation therefore performed primarily by the pleadings. o The various modes or instruments of discovery are meant to serve (1) as a device to narrow and clarify the basic issues between the parties, and (2) as a device for ascertaining the facts relative to those issues. - 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. - In this case, the motion filed by the Sps. Uy was for a good cause because said documents were necessary for a full determination of the issues. - SBC likewise points out that there are 6 requisites to be complied with before a party may be compelled to produce documents for inspection, and these are: o The party must file a motion for the production/inspection showing good cause thereof. o Notice of the motion must be served to all parties. o The motion must designate the documents, papers, books, accounts, letters..etc. which the party wishes to be produced. o Such documents are not privileged. o Such documents constitute evidence material to any matter involved in the action.

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SECURITY BANK CORPORATION VS. COURT OF APPEALSPanganiban, J. | January 25, 2000

FACTS:- Security Bank Corporation (SBC) is one of the defendants in a Civil Case for injunction and damages.- The Sps. Uy sought to enjoin SBC from proceeding with the extrajudicial foreclosure of a mortgage over a piece of

land.- When this was denied, the Sps. Uy filed a motion to inhibit the judge which resulted in the re-raffling of the case.- SBC filed its answer with counterclaim and cross-claim, while Uy filed his answer also with counterclaim and cross-

claim.- Uy filed an Omnibus Motion on the ground that all documents, papers and instruments must be first produced before

they could prepare and file their answers to SBC.- Acting on said motion, the TC granted such and ordered SBC to produce all its documents pertaining to the

mortgage.- CA: affirmed the TC

ISSUE:- WON the CA erred in affirming the grant by the lower court of the motion for the production and inspection of

documents.HELD:

- NO.RATIO:

- Section 1, Rule 27 of the Rules of Court allows the parties to, upon a showing of good cause, file with the court to:o Order any party ot produce and produce the inspection and copying of paper, books and accounts or any

matter involved in the action.o Order any party to permit entry upon land or property in his possession for the purpose of inspecting the

same.- In Republic vs. Sandiganbayan

o The court held that the said Rule aims to enable the parties to inform themselves, even before 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.

o The deposition-discovery procedure was designated to remedy the conceded inadequacy and cumbersomeness of the pre-trial functions of notice-giving, issue-formulation and fact revelation therefore performed primarily by the pleadings.

o The various modes or instruments of discovery are meant to serve (1) as a device to narrow and clarify the basic issues between the parties, and (2) as a device for ascertaining the facts relative to those issues.

- 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.

- In this case, the motion filed by the Sps. Uy was for a good cause because said documents were necessary for a full determination of the issues.

- SBC likewise points out that there are 6 requisites to be complied with before a party may be compelled to produce documents for inspection, and these are:

o The party must file a motion for the production/inspection showing good cause thereof.o Notice of the motion must be served to all parties.o The motion must designate the documents, papers, books, accounts, letters..etc. which the party wishes to

be produced.o Such documents are not privileged.o Such documents constitute evidence material to any matter involved in the action.o Such documents are in the possession, custody or control of the other party.

- SBC argues that the 6th requisite is absent.- The SC held that the documents were relevant in that they were necessary so that the Sps. Uy can determine why

SBC was going after their property which was invalidly mortgaged, while the properties of the actual borrower, have not been touched or foreclosed.