G.R. No. L-25137; July 28, 1969
J. P. JUAN & SONS, INC., represented by its Treasurer, Rodolfo S. Juan, plaintiff-appellee, vs. LIANGA INDUSTRIES, INC., defendant-appellant.

FACTS

Plaintiff J. P. Juan & Sons, Inc. filed a complaint in the City Court of Manila to recover from defendant Lianga Industries, Inc. the sum of P900.00, representing the unpaid balance for office equipment sold and delivered under a purchase order dated October 15, 1962, for a total price of P1,890.00. The complaint included a copy of the purchase order as an annex. The City Court ruled in favor of the plaintiff. The defendant appealed to the Court of First Instance of Manila. In its Answer, the defendant “denied specifically all the allegations of paragraphs 2 and 3 of the complaint” (the material allegations concerning the purchase, partial payment, and failure to pay the balance) and alleged as a special and affirmative defense that “defendant has no obligation to pay to the plaintiff the amount or sum of money claimed in the complaint.” The defendant did not deny under oath the authenticity of the annexed purchase order as required by the Rules of Court. During pre-trial, the plaintiff submitted a list of its documentary evidence and moved for judgment on the pleadings. The lower court granted the motion, ruling that the defendant’s denials were mere general denials that amounted to admissions of the complaint’s material allegations. It rendered judgment for the plaintiff. The defendant appealed, and the Court of Appeals certified the case to the Supreme Court as it involved only issues of law.

ISSUE

Whether the lower court correctly rendered a judgment on the pleadings by ruling that the defendant’s “specific denials” in its Answer were, in law, mere general denials that failed to tender an issue and thus admitted the material allegations of the complaint.

RULING

Yes, the lower court correctly rendered judgment on the pleadings. The Supreme Court affirmed the judgment. The defendant’s Answer, which “denied specifically” the material allegations without setting forth the substance of the matters relied upon for the denial, constituted a general denial under Rule 8, Section 10 of the Revised Rules of Court. Such a denial fails to tender an issue. Furthermore, the defendant’s failure to deny under oath the authenticity of the purchase order annexed to the complaint resulted in a deemed admission of its genuineness and due execution under Rule 8, Section 8. The defendant’s affirmative defense of having “no obligation to pay” was a mere conclusion of law unsupported by allegations of material fact. Since the Answer failed to properly tender any issue, and the material allegations of the complaint were deemed admitted, the plaintiff was entitled to a judgment on the pleadings under Rule 19, Section 1. The Supreme Court reiterated the established doctrine from El Hogar Filipino vs. Santos Investments, Inc. that a general denial, even if termed “specific,” does not comply with the rules and entitles the plaintiff to judgment on the pleadings.