Lime v. Marcaida

Summary

This Supreme Court En Banc decision established the scope of bill of discovery in Philippine jurisprudence. Petitioners sought prohibition against a trial court order requiring production of corporate records through subpoena duces tecum. The Court recognized that while no specific bill of discovery exists in Philippine codes, sections 355 and 402 of the Code of Civil Procedure authorize similar remedies for depositions and document production. The Court held that trial judges have discretionary control over such proceedings, applying tests of reasonableness and practicability. The remedy applies only to relevant, sufficiently described documents in opponent's possession, and cannot be used for fishing expeditions. Finding no abuse of discretion, the Court denied the petition, establishing important precedent for pre-trial discovery procedures and judicial discretion in compelling document production.