Young v. Young
REITERATIONFacts
The Antecedents: The plaintiff-appellee, Salud Young, filed a complaint against the defendant-appellant, Olivia Young, for the payment of P3,600.00 with interest. Procedural History: The City Court of Cebu rendered a judgment on the pleadings ordering the defendant-appellant to pay the plaintiff-appellee the sum of P3,600.00 with 6% interest per annum from April 14, 1969, plus attorney's fees and costs. The Court of First Instance of Cebu affirmed this judgment. The Appeal: The defendant-appellant appealed the decision to the Court of Appeals, which was subsequently certified to the Supreme Court due to a legal question involving the interpretation of the Rules of Court.
Issue(s)
Whether or not the City Court of Cebu erred in issuing a judgment on the pleadings on the ground that the defendant failed to enter a verified specific denial of the genuineness and due execution of the written instruments which were made the basis of the action pursuant to Section 7, Rule 8 of the Rules of Court.
Ruling
The Supreme Court affirmed the judgment of the lower court. No costs.
Ratio Decidendi
On the Issue of Judgment on the Pleadings: The Court held that the City Court of Cebu did not err in rendering a judgment on the pleadings because the substance of the written instruments, which formed the basis of the action, were properly alleged in the complaint, and copies thereof were attached to the complaint. The defendant-appellant failed to file a verified specific denial of the genuineness and due execution of these documents, resulting in an implied admission of their authenticity and due execution under Section 8 of Rule 8 of the Rules of Court. Consequently, no issue was sufficiently tendered as to require a trial, making a judgment on the pleadings appropriate. The Court reiterated that the purpose of requiring a sworn denial is to place the genuineness and due execution of the instrument in issue, and without such a denial, the instrument is deemed admitted. Therefore, the judgment rendered by the City Court was in accordance with the rules and established jurisprudence.
Main Doctrine
The Supreme Court affirmed that a judgment on the pleadings is appropriate when a defendant fails to file a verified specific denial of the genuineness and due execution of written instruments presented by the plaintiff. Such failure constitutes an implied admission of the authenticity and due execution of these documents, as per Sections 7 and 8 of Rule 8 of the Rules of Court, thereby obviating the need for further trial.