Roman Catholic Apostolic Church v. Municipality of Badoc
REITERATIONFacts
The Antecedents: Plaintiffs, the Roman Catholic Apostolic Church and others, initiated an action under Act No. 1376 to recover possession of churches, convents, cemeteries, and other properties located in Ilocos Norte. They alleged ownership and right to possession. Procedural History: Defendants, including the Municipality of Badoc, presented an answer containing a general denial of the complaint's allegations and several affirmative defenses. Subsequently, the plaintiffs filed a motion seeking to have the allegations in their complaint deemed admitted and to order the dispossession of the defendants, arguing that the defendants' answer did not conform to Section 4 of Act No. 1376. The Petition: The plaintiffs' motion essentially sought a judgment by confession due to the alleged non-conformity of the defendants' answer with the specific requirements of Section 4 of Act No. 1376. The core of the plaintiffs' argument was that the defendants' general denial was insufficient under the said Act, and therefore, the allegations of the complaint should be taken as true.
Issue(s)
Whether a general denial in an answer is sufficient under Section 4 of Act No. 1376. Whether the plaintiffs' motion to declare allegations admitted and order dispossession should be granted.
Ruling
The Supreme Court denied the plaintiffs' motion. It held that the general denial contained in the defendants' answer was sufficient. The Court also denied the motion filed by defendant Aglipay and the municipality of Dingras, which sought to declare Act No. 1376 unconstitutional.
Ratio Decidendi
On Issue 1: The Court held that a general denial in an answer is sufficient under Section 4 of Act No. 1376, as there is nothing in the section that expressly prohibits such a denial. The Court reasoned that every system of judicial procedure presupposes allegations on one side and admissions or denials on the other, and issues can only be raised by denials. While Section 4 requires defendants to deny specific aspects of the plaintiff's claim, this should not be construed to prevent a general denial of other allegations. The Court further noted that if a general denial were not permissible, then specific denials of particular facts would also be restricted, which would unduly limit the defendant's ability to contest the complaint. The Court emphasized that no law establishing a special procedure should be interpreted to prohibit a denial unless there is a clear and unequivocal prohibition. On Issue 2: The Court denied the plaintiffs' motion to declare the allegations admitted and order dispossession. The Court found that the general denial in the answer was sufficient to raise an issue, thus preventing the allegations from being taken as confessed. Furthermore, the Court stated that even if the answers were defective in not containing all the allegations required by Section 4, the plaintiffs should have filed a motion requiring the defendants to amend their answers rather than moving to strike out all the answers. The Court also noted that if any one answer was good, the motion to strike out all answers would have to be denied. The Court also addressed the motion by defendant Aglipay and the municipality of Dingras to declare Act No. 1376 unconstitutional, stating that this objection was set forth as a special defense and should be tried on the merits, declining to consider it at that stage.
Main Doctrine
The Supreme Court reiterated that in the absence of a clear and unequivocal prohibition in a special statute, a general denial in a defendant's answer is permissible and sufficient to raise an issue. The Court emphasized that every system of judicial procedure presupposes allegations and denials, and issues can only be raised by denials. If a pleading is defective, the opposing party should move for an amendment rather than seeking to have the entire pleading stricken out, thereby denying the defendant an opportunity to present their defense on the merits.