Baetamo v. Samson
REITERATIONFacts
The Antecedents: Petitioner, as special administratrix of the estate of Geronima Baetamo y Gonzales, filed three civil actions against respondent Leon M. Samson and his co-respondents. The first two actions sought to annul sales of land made by Samson, the surviving husband, to his co-respondents, alleging the sales were fictitious and intended to defraud the heirs. The third action aimed to prevent Samson from disposing of remaining conjugal partnership properties with intent to defraud the heirs. Procedural History: The defendants filed answers consisting of a general denial of all allegations and a reservation to file amended answers. The cases were consolidated. Petitioner moved for judgment on the pleadings, arguing the answers did not raise issues and constituted implied admissions. The respondent judge denied the motion, citing that the answers contained specific denials and a reservation to amend, and that the doctrine in El Hogar Filipino was not applicable because the answers did not contain a reservation. The judge also invoked liberal construction of pleadings. The Petition: Petitioner filed a petition for certiorari and mandamus to set aside the respondent judge's order denying the motion for judgment on the pleadings and to compel the judge to render judgment on the pleadings.
Issue(s)
Whether the answers filed by the respondents constitute a general denial or a specific denial. Whether the reservation to file an amended answer has any legal effect.
Ruling
The Court granted the petition, setting aside the order of the respondent judge and ordering the judge to render judgment on the pleadings. The Court ruled that the answers were general denials and the reservation to amend was without legal effect.
Ratio Decidendi
On the nature of the answers: The Court held that the answers filed by the respondents were general denials, despite being phrased as "specifically den[ying] each and every allegation contained in each and every paragraph of the complaint." The Court emphasized that calling a denial "specific" does not make it so, and that a true specific denial requires dealing with each material allegation of fact and, whenever practicable, setting forth the substance of the matters relied upon to support the denial, as mandated by Sections 6 and 7 of Rule 9 of the Rules of Court. The Court reiterated its pronouncement in El Hogar Filipino vs. Santos Investments, Inc. that such a broad denial is merely a general denial, failing to serve the purpose of limiting issues and avoiding surprise. On the effect of the reservation to amend: The Court found no provision in the Rules of Court that permits a reservation to file an amended answer to have legal effect. Such a reservation would defeat the time limits for filing responsive pleadings. The Court clarified that under Section 1 of Rule 17, a party may amend a pleading as a matter of course only before a responsive pleading is served, or within ten days after service if no responsive pleading is permitted and the case has not been placed on the trial calendar. Since the defendants did not amend their answers within the prescribed period and after the cases had been set for trial, the reservation had no legal standing. The Court concluded that the petitioner's motion for judgment on the pleadings was therefore in order and should have been granted.
Main Doctrine
A general denial, even if couched in specific terms, does not tender an issue and constitutes an implied admission of the material allegations of the complaint. A reservation to file an amended answer does not cure a defective answer nor extend the period for amendment as a matter of course.