Juan & Sons v. Liangga Industries
REITERATIONFacts
1. The Antecedents: Plaintiff J. P. Juan & Sons, Inc. filed a complaint against defendant Lianga Industries, Inc. for the recovery of P900.00, representing the unpaid balance for office equipment amounting to P1,890.00, sold and delivered on October 15, 1962. Plaintiff also sought legal interest, costs, and attorney's fees. 2. Procedural History: The City Court of Manila rendered judgment in favor of the plaintiff. The defendant appealed to the Court of First Instance (CFI) of Manila. The defendant filed an Answer denying specifically paragraphs 2 and 3 of the complaint, which pertained to the purchase, partial payment, and refusal to pay the balance. As an affirmative defense, the defendant stated it had no obligation to pay. The defendant did not deny under oath the authenticity of the purchase order annexed to the complaint. At the pre-trial conference, the plaintiff moved for judgment on the pleadings, citing the defendant's answer and lack of denial under oath. The CFI granted the motion, finding that the defendant's denials were general and amounted to admissions of the material allegations. The defendant appealed to the Court of Appeals, which certified the case to the Supreme Court as it involved only questions of law. 3. The Petition: The defendant appealed the CFI's decision granting judgment on the pleadings. The Court of Appeals certified the case to the Supreme Court because it involved only questions of law, specifically whether the defendant's answer tendered issues of fact. The Supreme Court found the appeal frivolous, affirming the CFI's ruling that the defendant's "specific denials" were legally general denials amounting to admissions, and that its affirmative defense was a mere conclusion. The Court also noted the defendant's failure to deny the purchase order's authenticity under oath, which constituted an admission of its genuineness and due execution. The Supreme Court affirmed judgment with treble costs against the defendant-appellant.
Issue(s)
Whether the defendant's "specific denial" and "affirmative defense" in its Answer failed to tender an issue, thereby entitling the plaintiff to a judgment on the pleadings. Whether the defendant's failure to deny under oath the authenticity of the purchase order annexed to the complaint constituted an admission of its genuineness and due execution.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, holding that the defendant's answer failed to tender an issue and that the plaintiff was entitled to a judgment on the pleadings. The Court also found the defendant's appeal to be frivolous.
Ratio Decidendi
On the failure to tender an issue: The Court reiterated the established doctrine that a general denial, even if termed a "specific denial," fails to tender an issue and entitles the plaintiff to a judgment on the pleadings. The defendant's answer, which "denied specifically all the allegations of paragraphs 2 and 3 of the complaint" and asserted an "affirmative defense" that it "has no obligation to pay," was deemed insufficient. Such denials, when the matters alleged are plainly within the defendant's knowledge, are considered evasive and do not comply with the requirement of Rule 8, Section 10 of the Revised Rules of Court, which mandates that a defendant must specify each material allegation of fact the truth of which he does not admit and set forth the substance of the matters he will rely upon to support his denial. The defendant's "affirmative defense" was also considered a mere conclusion of law, not premised on any allegation of material facts. On the failure to deny under oath the authenticity of the purchase order: The Court affirmed the lower court's finding that the defendant's failure to deny under oath the authenticity of the purchase order annexed to the complaint, as required by Rule 8, Section 8 of the Revised Rules of Court, constituted an admission of its genuineness and due execution. This failure, coupled with the insufficient denial of the complaint's material allegations, meant that the material allegations of the complaint, including the purchase of office equipment, delivery, partial payment, and the outstanding balance, were deemed admitted by the defendant. The Court rejected the defendant's contention that the purchase order was merely an offer, as it was contradicted by the admitted facts of delivery and partial payment.
Main Doctrine
A general denial, even if termed a 'specific denial,' fails to tender an issue and entitles the plaintiff to a judgment on the pleadings, especially when the authenticity of an annexed document is not denied under oath.