Trias v. Court of First Instance
REITERATIONFacts
The Antecedents: Petitioner Maximo C. Trias instituted Civil Case No. 193 against respondents for the partition of a 100-hectare parcel of land inherited from their common ancestor, Balbino Trias. The complaint alleged that the land was community property, administered by General Mariano Trias and his widow until 1926. From 1926 onwards, respondent Miguel F. Trias allegedly administered the property, deriving an income of at least P3,000 per annum, but failed to render an accounting or distribute the proceeds despite demands. The complaint also stated that other heirs of General Mariano Trias and heirs of Constancia Trias refused to partition the property. Procedural History: Five defendants, children of the deceased General Mariano Trias, filed an answer "ad cautelam" admitting only the parties' residences and capacity to sue, but generally denying all other allegations, with a reservation to file an amended answer. The plaintiff (petitioner) moved for judgment on the pleadings, arguing the answer was insufficient. Subsequently, these five defendants filed an amended answer with special defenses, asserting partition of the properties, adverse possession for over thirty years by Mariano Trias's successors, and prescription of the plaintiff's cause of action. They also opposed the motion for judgment on the pleadings. The respondent court, after a hearing, admitted the amended answer and denied the motion for judgment on the pleadings. The Petition: Petitioner filed a certiorari to annul the order admitting the amended answer and denying the motion for judgment on the pleadings, alleging that the respondent court acted without jurisdiction or with grave abuse of discretion.
Issue(s)
Whether the trial court committed grave abuse of discretion in admitting an amended answer after a motion for judgment on the pleadings was filed. Whether the implied admission of allegations under Rule 9 resulting from a failure to specifically deny is irrevocable.
Ruling
The petition is denied and the order complained of is affirmed.
Ratio Decidendi
On Issue 1: The Supreme Court held that the trial court did not abuse its discretion under Rule 17, Section 2, which allows for the amendment of pleadings 'at any stage of an action' to ensure the 'real matter in dispute' is determined. The Court noted that the defendants provided a satisfactory explanation for the delay, citing their activities in the resistance movement during the Japanese occupation. The amendment was sought before the case was set for trial and before the motion for judgment on the pleadings was heard, indicating no intent to delay. Furthermore, since the complaint claimed over P50,000 in damages, Section 8 of Rule 9 would still require proof of the amount of damages even if other allegations were admitted. Thus, the admission of the amended answer was in consonance with law and justice to allow a trial on the merits. On Issue 2: The Court ruled that the admission of material averments under Section 8 of Rule 9 is not irrevocable. Like any other judicial admission, it may be withdrawn with leave of court if there is a justifiable reason and the interests of justice require it. An answer consisting of a general denial may be amended under Section 2 of Rule 17 to replace the implied statutory admission with specific denials and special defenses. The Court distinguished the present case from El Hogar Filipino v. Santos Investments, Inc., noting that in the latter, the defendant never sought to amend the answer. Consequently, the trial court maintains the authority to allow a party to correct a defective denial to prevent a judgment based on technicality rather than the true facts of the dispute.
Main Doctrine
The admission of material averments in a complaint is not irrevocable and may be withdrawn with leave of court if there is a justifiable reason and the interests of justice require it. An answer with a general denial may be amended, with leave of court, to remove the implied statutory admission.