Laqui v. Sagun
REITERATIONFacts
The Antecedents: Gregorio Espejo died intestate, leaving a property covered by OCT No. 201800169. Pursuant to a Memorandum of Agreement, the property was subdivided, and Lot 1 was given to respondents Alex E. Sagun, Nelia S. Espiritu, and Katherine Marie T. Sagun (Sagun et al.) as heirs of Remedios E. Sagun. Respondents alleged that Remedios and petitioner Rolly B. Laqui, Sr. (Laqui) entered into a lease agreement over the subject property in 2002, which was implicitly renewed on a month-to-month basis after its expiration. On March 19, 2019, Sagun et al. demanded Laqui to vacate the premises. After their demand was unheeded, they filed a complaint for ejectment before the barangay. An Amicable Settlement was reached on September 24, 2019, wherein Laqui agreed to vacate the property within six months (until March 2020) and pay a monthly rental of PHP 5,300.00. Laqui failed to comply with the settlement. Procedural History: Sagun et al. filed a complaint for the enforcement of the Amicable Settlement before the Municipal Trial Court in Cities (MTCC). In his Answer, Laqui denied the allegations and raised an affirmative defense that the property was assigned to him by the Estate of Acopiado's administrator, Daniel Franieza, via a Deed of Assignment dated October 30, 2019. Sagun et al. filed a Motion for Judgment on the Pleadings, which the MTCC granted, holding that Laqui admitted the material allegations due to his insufficient denial and that his affirmative defense was resolved by the Amicable Settlement, which had the effect of res judicata. Laqui was ordered to vacate and pay rentals. The MTCC denied his motion for reconsideration. Laqui appealed to the Regional Trial Court (RTC), arguing that a pretrial should have been conducted and his affirmative defense denied. The RTC affirmed the MTCC ruling, stating no rule requires pretrial before judgment on the pleadings and that Laqui's denial was improper. The RTC also disallowed his affirmative defense due to defects in his Judicial Affidavit and the Deed of Assignment, and because he was estopped from denying the lessor's title. The RTC denied his motion for reconsideration. Laqui then filed a Petition for Review with the Court of Appeals (CA), reiterating his arguments. The CA affirmed the RTC decision in toto, finding that the judgment on the pleadings was proper as Laqui's Answer failed to tender an issue and that he was estopped from questioning the respondents' title. The Petition: Laqui filed a Petition for Review on Certiorari under Rule 45, arguing that the CA erred in affirming the RTC decision, specifically on the propriety of rendering a judgment on the pleadings without a pretrial conference and in denying his affirmative defense.
Issue(s)
Whether the Court of Appeals erred in affirming the Regional Trial Court's decision holding that the judgment on the pleadings was properly rendered even without a pretrial conference. Whether the Court of Appeals erred in affirming the Regional Trial Court's denial of the petitioner's affirmative defense.
Ruling
The petition is denied. The Court held that the rendition of a judgment on the pleadings by the MTCC was improper, but it should be considered a summary judgment. The Court affirmed the lower courts' rulings that a pretrial conference is not a prerequisite for rendering a judgment on the pleadings or a summary judgment, and that the petitioner is estopped from denying the respondents' title.
Ratio Decidendi
On the propriety of judgment on the pleadings and the absence of pretrial conference: The Court found that the rendition of a judgment on the pleadings by the MTCC was improper because Laqui interposed an affirmative defense. However, the Court clarified that the judgment should be considered a summary judgment. The Court reiterated that a pretrial conference is not a prerequisite for rendering a judgment on the pleadings or a summary judgment. The Court explained that if the pleadings fail to tender an issue or raise a genuine issue of fact, a trial is dispensed with, making a pretrial unnecessary. The purpose of judgment on the pleadings and summary judgment is to expedite the disposition of cases by avoiding unnecessary trials when facts are undisputed or issues are sham. Therefore, Laqui's contention that a pretrial must precede such judgments is untenable and antithetical to the objective of speedy and inexpensive disposition of cases. On the denial of the affirmative defense: The Court held that Laqui's affirmative defense, which claimed assignment of the property to him, did not present a genuine issue requiring a full-blown trial because he is estopped from denying the title of the respondents as lessors. This estoppel is based on Article 1436 of the Civil Code and Section 2(b) of Rule 131 of the Rules of Court. The Court found no change in the nature of the respondents' title subsequent to the commencement of the lessor-lessee relationship. Laqui's claim of a subsequent change through a Deed of Assignment was not sufficiently proven, and he failed to establish the authority of the alleged administrator to execute such a deed. Furthermore, even if the deed were valid, it stemmed from an alleged title that Laqui is estopped from invoking to deny the respondents' title. The Court also noted that the issue of ownership raised by Laqui is a question of fact, which is generally not reviewable under Rule 45, and no exceptions apply here.
Main Doctrine
A judgment on the pleadings is improper when an affirmative defense is interposed, as it raises a genuine issue of fact. In such cases, the court should consider rendering a summary judgment if the affirmative defense does not present a genuine issue requiring trial. Furthermore, a pretrial conference is not a prerequisite for rendering a judgment on the pleadings or a summary judgment.