A party defending against a claim based on an assigned credit, especially a credit in litigation, has the right under the rules of discovery (Rule 27) to compel the production of documents like a Loan Sale and Purchase Agreement (LSPA) that are explicitly mentioned in the Deed of Assignment and necessary to determine the consideration paid, particularly when invoking the right of legal redemption under Article 1634 of the Civil Code.

Export and Industry Bank (EIB) initiated a collection suit against Eagleridge Development Corporation (EDC) and its sureties, Marcelo N. Naval and Crispin I. Oben, for an outstanding loan obligation. During the pendency of this suit, EIB assigned EDC's loan obligation to Cameron Granville 3 Asset Management, Inc. (Cameron), a special purpose vehicle, through a Deed of Assignment which referenced an underlying Loan Sale and Purchase Agreement (LSPA). Cameron was subsequently substituted as the plaintiff in the collection case.

• EIB filed a collection suit against petitioners EDC, Naval, and Oben before the RTC Makati for an outstanding loan obligation of P10,232,998.00.
• On August 9, 2006, EIB executed a Deed of Assignment transferring EDC's loan obligation to respondent Cameron Granville 3 Asset Management, Inc. (Cameron).
• The Deed of Assignment explicitly stated it was pursuant to a Loan Sale and Purchase Agreement (LSPA) dated April 7, 2006, between EIB (Seller) and Cameron (Purchaser), and that defined terms in the Deed had the meaning given in the LSPA. The Deed only mentioned "For value received" regarding consideration.
• Cameron filed a Motion to Substitute/Join EIB, which the RTC granted.
• On February 22, 2012, petitioners filed a Motion for Production/Inspection of the LSPA dated April 7, 2006, referenced in the Deed of Assignment.
• Petitioners argued the LSPA was needed to ascertain the actual price Cameron paid for the loan, invoking their right under Article 1634 of the Civil Code to extinguish the debt (a credit in litigation) by reimbursing the assignee (Cameron) for the price paid, judicial costs, and interest.
• The RTC denied the motion on March 28, 2012, finding no "good cause" shown and that the LSPA was not material or relevant.
• Petitioners' Motion for Reconsideration, arguing the relevance of the LSPA for their Article 1634 rights (supported by the SPV Law, RA 9182), was denied by the RTC on May 28, 2012.
• Petitioners filed a Rule 65 certiorari petition with the CA, which dismissed it initially for procedural defects (lack of Oben's verification/certification, failure to attach complaint copy) and later, upon MR, found no grave abuse of discretion by the RTC.

• The production of the LSPA is necessary under Rule 27 as there is "good cause" because it contains the actual consideration paid by Cameron for the assigned credit, which is essential for petitioners to exercise their right of legal redemption under Article 1634 of the Civil Code.
• The LSPA is material and relevant because the Deed of Assignment explicitly refers to it and incorporates its terms by reference, making it necessary for understanding the full transaction under Rule 132, Section 17.
• Article 1634 of the Civil Code applies to the assignment, allowing petitioners (debtors) to extinguish the litigated credit by reimbursing Cameron the actual price paid, and the SPV Law (RA 9182) does not preclude, but rather supports, the application of Civil Code provisions on assignment of credits.
• The CA erred in dismissing their petition on technicalities, as Oben signed the verification/certification in his personal capacity, and a machine copy of the complaint is permissible under Rule 65.
• Denial of the motion for production constitutes grave abuse of discretion as it impairs their fundamental right to due process and access to relevant evidence crucial for their defense.

• Petitioners failed to show "good cause" for the production of the LSPA as required by Rule 27.
• The LSPA is irrelevant and immaterial to the collection case; the Deed of Assignment sufficiently proves Cameron's acquisition of the credit.
• The production of the LSPA is unnecessary to apprise petitioners of the consideration paid by Cameron.
• If petitioners believe the LSPA is important, they should obtain it from the Bangko Sentral ng Pilipinas, not from respondent, as it was not marked as an exhibit by respondent.

• Whether the Court of Appeals erred in dismissing the petitioners' Rule 65 petition based on technical grounds (defective verification/certification and attachment of a mere machine copy of the complaint).
• Whether the Regional Trial Court committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying the petitioners' motion for production and inspection of the Loan Sale and Purchase Agreement (LSPA).

• The Supreme Court granted the petition, reversing and setting aside the resolutions of the Court of Appeals.
• The Court held that the CA erred in dismissing the petition on technicalities; Oben's verification/certification was valid as he signed in his personal capacity as an impleaded party, and attaching machine copies of relevant pleadings is permitted under Rule 65.
• The Court found that the RTC committed grave abuse of discretion in denying the motion for production of the LSPA.
• The LSPA is relevant and material because the Deed of Assignment, respondent's primary evidence, explicitly refers to it and incorporates its terms, making the LSPA essential for understanding the assignment transaction under Rule 132, Section 17.
• The LSPA is necessary for petitioners to determine the actual consideration paid by Cameron, which is crucial for exercising their right of legal redemption under Article 1634 of the Civil Code, applicable even to transfers under the SPV Law (RA 9182, Sec. 13).
• Denying access to the LSPA violates the principles of discovery, which mandate broad and liberal access to relevant information to ensure fair trial and prevent litigation from being a "game of skills and stratagems."
• Respondent Cameron was ordered to produce the LSPA dated April 7, 2006, including annexes, for petitioners' inspection and photocopying.

• Motion for Production or Inspection (Rule 27, Rules of Court): Definition: A mode of discovery allowing a party, upon showing good cause, to request the court to order another party to produce and permit inspection and copying of designated documents relevant to the action and in the latter's possession. Application: The Court held petitioners showed "good cause" as the LSPA was relevant to their defense (Art. 1634) and explicitly mentioned in the Deed of Assignment, making its production essential under Rule 27.
• Relevance of Evidence / Whole of Writing (Rule 132, Section 17, Rules of Court): Definition: When part of a writing is offered in evidence, the whole of the same subject may be inquired into by the other party; when a detached writing is necessary to understand another writing given in evidence, it may also be admitted. Application: Since the Deed of Assignment was presented by respondent and explicitly referenced the LSPA for its terms (including consideration), the LSPA became relevant and subject to inquiry by petitioners under this rule.
• Assignment of Credit in Litigation (Article 1634, Civil Code): Definition: Grants the debtor the right to extinguish a credit or incorporeal right in litigation by reimbursing the assignee the price paid, judicial costs, and interest from the date of payment, within 30 days from the assignee's demand. Application: The Court affirmed the applicability of this article, stating petitioners had the right to know the price paid (contained in the LSPA) to potentially exercise this right of legal redemption against Cameron.
• Special Purpose Vehicle Act (RA 9182): Definition: A law facilitating the resolution of banks' non-performing assets by allowing their transfer to SPVs. Application: The Court noted Section 13 explicitly states that Civil Code provisions on subrogation and assignment of credits apply to NPL transfers under the Act, thus supporting the application of Article 1634. Section 19 also acknowledges the applicability of redemption periods under other laws.
• Liberal Construction of Discovery Rules: Definition: Procedural rules on discovery mechanisms (like production of documents) should be interpreted broadly and liberally to enable parties to obtain the fullest possible knowledge of relevant facts, ensuring fairness and expediting trials. Application: The Court applied this principle to mandate the production of the LSPA, emphasizing that parties should lay their cards on the table.
• Grave Abuse of Discretion: Definition: An error of judgment so patent and gross as to amount to an evasion of positive duty or a virtual refusal to perform a duty enjoined by law, or to act at all in contemplation of law, as where the power is exercised in an arbitrary or despotic manner by reason of passion or hostility. Application: The RTC's denial of the motion for production, despite the clear relevance and necessity of the LSPA for petitioners' defense and right of redemption, was deemed unreasonable, arbitrary, and thus constituted grave abuse of discretion correctible by certiorari.
• Due Process: Definition: The fundamental right to be heard and have a fair opportunity to present one's side in a legal proceeding. Application: The Court implied that denying access to crucial evidence like the LSPA would impair the petitioners' fundamental right to due process by hindering their ability to mount a proper defense.

• "All documents mentioned in a Deed of Assignment transferring the credit of the plaintiff in a pending litigation should be accessible to the defendant through a Motion for Production or Inspection of Documents under Rule 27 of the Rules of Court."
• "Litigation is not a game of skills and stratagems. It is a social process that should allow both parties to fully and fairly access the truth of the matters in litigation."
• "Generally, the scope of discovery is to be liberally construed so as to provide the litigants with information essential to the fair and amicable settlement or expeditious trial of the case. All the parties are required to lay their cards on the table so that justice can be rendered on the merits of the case."
• "Fair play demands that petitioners must be given the chance to examine the LSPA."
• "Section 13 of the SPV Law clearly provides that 'in the transfer of the Non-Performing Loans (NPLs), the provisions on subrogation and assignment of credits under the New Civil Code shall apply.'"
• "It must be remembered that '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.'"

• Heirs of Sofia Nanaman Lonoy v. Secretary of Agrarian Reform (2008), Garcia, Jr. V. CA (2008), OSM Shipping Philippines, Inc. V. NLRC (2003): Cited to support the procedural point that under Rule 65, petitioners could attach mere machine copies (not necessarily certified true copies) of relevant pleadings like the original complaint to their certiorari petition.
• Republic v. Sandiganbayan (1991): Cited to establish the purpose of discovery mechanisms under the Rules of Court – to enable parties and the court to discover all relevant and material facts. Also cited for the principle of liberal construction of discovery rules.
• Fortune Corporation vs. Court of Appeals (1994): Cited for the principle that the scope of discovery should be liberally construed. Also cited regarding the standard for reviewing discretionary acts related to discovery – reversal is warranted for clear or serious abuse of discretion.
• Koh v. IAC (1986): Cited for the principle that parties should lay their cards on the table through discovery so justice can be rendered on the merits.
• Alberto v. COMELEC (1999): Cited for the principle that while granting a motion for production is discretionary, it cannot be arbitrarily or unreasonably denied as this would impair the fundamental right to due process.
• Lime Corporation of the Philippines v. Moran (1933): Cited for the test in determining the relevancy of documents for production: reasonableness and practicability.
• Producers Bank of the Philippines v. CA (1998): Cited as an example where the exercise of discretion pertaining to discovery was set aside due to abuse or improvidence affecting substantial rights.
• Santos v. Phil. National Bank (2002): Cited for the principle that judicial discretion should be sound and exercised with due regard to the rights of parties and demands of equity and justice.
• Security Bank Corporation v. CA (2000): Cited for the principle that rules on discovery are accorded broad and liberal interpretation to enable parties to obtain the fullest possible knowledge of issues and facts, even those known only to adversaries, to prevent trials "in the dark." Also cited for the quote regarding litigation as a quest for truth requiring good faith disclosure.

• Rules of Court, Rule 27, Section 1 (Motion for production or inspection; order): Basis for the petitioners' motion to compel production of the LSPA.
• Rules of Court, Rule 132, Section 17 (Evidence: When part of writing or record given in evidence, the whole of the same subject may be inquired into by the other): Used to argue the relevance of the LSPA as it was referenced in the Deed of Assignment presented by the respondent.
• Rules of Court, Rule 45 (Appeal by Certiorari to the Supreme Court): The procedural basis for the petition filed before the Supreme Court.
• Rules of Court, Rule 65 (Certiorari, Prohibition and Mandamus): The procedural basis for the petition filed before the Court of Appeals challenging the RTC's orders; also cited regarding requirements for attachments to the petition.
• New Civil Code, Article 1634 (Legal Redemption in Assignment of Credit in Litigation): The substantive basis for petitioners' claim that they needed the LSPA to determine the price for exercising their right to extinguish the litigated credit.
• Republic Act No. 9182 (Special Purpose Vehicle Act of 2002), Section 12 (Notice and Manner of Transfer of Assets): Cited by petitioners in the lower court to support their arguments, although the SC focused more on Section 13.
• Republic Act No. 9182 (Special Purpose Vehicle Act of 2002), Section 13 (Application of Civil Code Provisions): Cited by the Supreme Court to confirm that Civil Code provisions on assignment of credit (including Art. 1634) apply to transfers of NPLs to SPVs.
• Republic Act No. 9182 (Special Purpose Vehicle Act of 2002), Section 19 (Redemption Periods): Cited by the Supreme Court to show the SPV law explicitly recognizes the applicability of redemption periods under the Rules of Court and other laws, supporting the relevance of Art. 1634.