Constantino v. Court of Appeals
REITERATIONFacts
The Antecedents: Lourdes Hisola alleged that Elizabeth Constantino was the offspring of her illicit relations with Casimiro Constantino, and that as a result, she suffered damages. Elizabeth was born on September 17, 1953. Lourdes was employed by Casimiro until February 2, 1953, and later transferred to another house. Two months after transferring, Lourdes admitted to her new employer that she was pregnant and identified Casimiro as the father. Procedural History: The Court of First Instance of Manila declared Elizabeth an illegitimate child of Casimiro and ordered him to pay P390 in support arrears and P30 monthly allowance, plus P500 for damages and P200 for attorney's fees and costs to Lourdes Hisola. The Court of Appeals reversed this decision, finding no evidence to establish Elizabeth as Casimiro's illegitimate child. The Petition: Petitioners seek to set aside the Court of Appeals' decision, arguing that Casimiro should be deemed to have admitted his illicit relations with Lourdes due to his general denial of the allegations in the complaint.
Issue(s)
Whether Casimiro Constantino's denial of paragraphs 4 and 5 of the complaint constitutes a general denial, thereby admitting the allegations of illicit relations and conception. Whether the Court of Appeals erred in reversing the trial court's decision despite the alleged admission by Casimiro.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, dismissing the petition for review. No pronouncement as to costs.
Ratio Decidendi
On the issue of Casimiro Constantino's denial: The Court held that Casimiro's denial of paragraphs 4 and 5 of the complaint was not a general denial but a specific denial. While the answer stated "defendant denies the averment contained in paragraphs 4 and 5 of the complaint," these paragraphs contained only one material allegation each, both of which were specifically denied. The Court clarified that a denial is not specific merely because it is qualified by the word 'specifically'; a denial of each and every allegation in each paragraph is general. However, in this case, the denial pertained to specific paragraphs containing distinct allegations. The Court cited Moran's Comments on the Rules of Court, emphasizing that the purpose of specific denial is to make the defendant disclose the matters he intends to disprove and to avoid unfair advantage and unnecessary expenses. The Court found that the denial in this case substantially complied with the rule, as it dealt specifically with the material allegations in the specified paragraphs. The fact that the plaintiff proceeded to trial and presented evidence on the alleged cohabitation indicated that she was not taken by surprise by the denial. On the issue of the Court of Appeals' reversal: The Court found no merit in the contention that Casimiro should be deemed to have admitted his illicit relations with Lourdes. The Court of Appeals, after analyzing the evidence, concluded that there was no sufficient proof to establish that Elizabeth Constantino was the illegitimate child of Casimiro Constantino. The Court noted that Lourdes' statement, "Ella es nuestra hija" (indicating the defendant Casimiro), was considered gratuitous without proof of the illicit relations. The Court found that the evidence presented by the plaintiff was insufficient or incompetent in the eyes of the Court of Appeals. The Court stated that the plaintiff's resort to technicality to remedy the deficiency in evidence could not be permitted, especially since she proceeded to trial and presented evidence on the alleged cohabitation.
Main Doctrine
A general denial, even if qualified by the word 'specifically,' is insufficient if it does not deal specifically with each material allegation of fact. However, a denial of specific paragraphs containing single material allegations is considered a specific denial. The failure to present sufficient evidence to prove an allegation, despite a denial, cannot be remedied by resorting to technicalities.