G.R. No. L-19762 December 23, 1964
ADOLFO B. BENAVIDES, plaintiff-appellee, vs. EDUARDO ALABASTRO, defendant-appellant.

FACTS

On August 26, 1955, the Municipal Court of Manila rendered a judgment ordering Eduardo Alabastro to pay Ajax International Corporation the sum of P274.85 with interest and attorney’s fees. On January 6, 1961, Ajax International Corporation assigned its rights under this judgment to Adolfo B. Benavides. After a demand for payment was not met, Benavides filed an action on January 26, 1962, before the Court of First Instance of Manila to recover the amount. Alabastro answered the complaint, stating for several paragraphs that he had “no knowledge or information sufficient to form a belief as to the truth” of the allegations and therefore specifically denied them, and also set up an affirmative defense that the claim had been extinguished and could not be validly assigned as it had not been revived. The plaintiff moved for judgment on the pleadings, which the trial court granted, rendering a decision in favor of Benavides. Alabastro appealed.

ISSUE

Whether the trial court erred in rendering a decision on a motion for judgment on the pleadings based on the defendant’s answer.

RULING

Yes, the trial court erred. The Supreme Court reversed the decision and remanded the case to the lower court for further proceedings. The Court held that a judgment on the pleadings is proper only when the pleading of the party against whom the motion is directed does not tender any issue or admits all the material allegations. Here, the defendant’s answer, by stating a lack of knowledge or information sufficient to form a belief as to the truth of the material allegations, had the effect of a denial under Section 10, Rule 8 of the Rules of Court, thereby tendering an issue. Furthermore, the answer set up affirmative defenses. The nature of such an answer necessitates the presentation of evidence, making it erroneous to render a decision without a hearing.