G.R. No. L-17454; July 31, 1963
CORNELIO ARROJO, plaintiff-appellee, vs. WENCESLAO CALDOZA, CALIXTA BALDERIAN, PASCUAL BALDERIAN, AGATON TOLOSA and BEBIANO LUBAN, defendants-appellants.

FACTS

Cornelio Arrojo filed an action in the Court of First Instance of Leyte to recover possession and ownership of a specific parcel of land located in Dagami, Leyte, from the defendants-appellants, and to claim damages. The defendants, in their answer, responded to the key paragraphs of the complaint alleging Arrojo’s ownership and their alleged unlawful occupation. Specifically, in paragraphs II and III of their answer, they stated they had “no knowledge or information sufficient to form a belief” as to the truth of Arrojo’s allegations regarding the description of the land and his ownership and possession.
Crucially, the defendants’ answer did not stop at this general denial. They proceeded to assert the “truth of the matter,” stating that they had not occupied any property belonging to Arrojo. They explicitly claimed that they were in possession and ownership of land belonging to them, which they inherited from their parents as predecessors-in-interest. They further alleged that Arrojo made no demand for them to vacate because he knew he was not the owner of the lands they occupied.

ISSUE

Whether the trial court correctly rendered a judgment on the pleadings in favor of the plaintiff-appellee on the ground that the defendants-appellants’ answer failed to tender an issue.

RULING

The Supreme Court reversed the trial court’s judgment and remanded the case for further proceedings. The legal logic is anchored on the rules governing pleadings and judgments on the pleadings. A judgment on the pleadings is proper only when the answer fails to tender any genuine issue of fact or law, effectively admitting the material allegations of the complaint. The Court held that the defendants’ answer in this case did tender a genuine and specific issue.
While the answer used the phrase “no knowledge or information sufficient to form a belief,” which can sometimes be considered a negative pregnant or an evasion, it did not end there. The defendants positively asserted an adverse claim of ownership and possession. By stating they owned and possessed the land through inheritance from their parents, they directly contradicted Arrojo’s claim of ownership and prior possession. This assertion transformed their response from a mere general denial into a specific denial that put the plaintiff’s title and right to possession in issue. Therefore, the answer sufficiently raised the central issues of ownership and possession, precluding a judgment on the pleadings. The case required a full trial where both parties could present evidence to substantiate their conflicting claims over the disputed property.