G.R. No. 85718 ; April 16, 1991
SPOUSES FEDERICO and ROSAMYRNA CARANDANG and F.V. CARANDANG, petitioners, vs. THE HON. COURT OF APPEALS and PUZON INDUSTRIAL DEVELOPMENT CORPORATION, respondents.

FACTS

Petitioners, the Carandang spouses and their corporation F.V. Carandang Construction, Inc., entered into a construction contract with respondent Puzon Industrial Development Corporation. The agreement stipulated that Puzon would build sixteen housing units at its own cost and would be paid from the sales proceeds of those units. Puzon completed the work but alleged it was paid only a fraction of the contract price. The Carandangs subsequently executed a General Assignment of their collectible accounts from lot buyers to Royal Monarch Real Estate Corporation and later, through a Memorandum of Agreement, assigned all receivables from the subdivision project, including from the houses Puzon built, to State Investment House, Inc. (SIHI) to secure a loan.
Puzon filed a complaint for collection of sum and damages against the Carandangs, Royal Monarch, and SIHI. It alleged the assignments were executed without its knowledge and deprived it of the sales proceeds earmarked for its payment. The defendants raised various defenses, including claims of construction defects and that Puzon’s claim should be directed at Royal Monarch. After pre-trial, the parties agreed to limit the issues to the amount of deductions claimed by the Carandangs and whether Puzon was entitled to share in amortizations received by SIHI.

ISSUE

Whether the trial court and the Court of Appeals erred in rendering a summary judgment against the petitioners.

RULING

No, the summary judgment was proper. The Supreme Court held that a summary judgment is appropriate when the pleadings, admissions, and documents on file show no genuine issue as to any material fact, leaving only a question of law for resolution. Here, the petitioners failed to raise any substantial factual issue that would necessitate a full trial. Their defenses, including the claim that the assignments to SIHI were made in good faith for a loan and did not constitute fraud, were deemed insufficient to create a genuine issue.
The legal logic is grounded in procedural rules. The petitioners were duly served with Puzon’s motion for summary judgment and its supporting documents. Their failure to file an opposition or appear at the scheduled hearing constituted a waiver. Furthermore, their failure to specifically deny under oath the genuineness and due execution of the actionable documents attached to the complaint, such as the construction contracts and assignment agreements, resulted in a judicial admission of those documents’ authenticity. Judicial admissions are binding and do not require proof. Since the material facts establishing Puzon’s causes of action for damages and specific performance were uncontested, the trial court correctly applied the law to these established facts. The appellate court’s affirmance was therefore valid, as the petitioners’ arguments essentially raised factual issues disguised as legal questions, which are not reviewable in a petition of this nature.