GR L 3007; (August, 1906) (Digest)
G.R. No. L-3007, August 3, 1906
FACTS:
The Roman Catholic Apostolic Church filed an action under Act No. 1376 to recover possession of various churches, convents, cemeteries, and other properties in Ilocos Norte from the Municipality of Badoc and other defendants. The defendants, through counsel, filed an answer containing a general denial of the complaint’s allegations and several affirmative defenses. Subsequently, the plaintiffs moved for a judgment declaring the complaint’s allegations admitted and for the return of the properties, arguing that the defendants’ answer failed to comply with the specific requirements of Section 4 of Act No. 1376 . The defendants, including Aglipay and the Municipality of Dingras, separately moved to declare the proceedings null and void and to challenge the constitutionality of Act No. 1376 .
ISSUE:
Whether the defendants’ answer, which included a general denial, was sufficient under Section 4 of Act No. 1376 , or whether the plaintiffs were entitled to a judgment based on the defendants’ alleged failure to file a proper answer.
RULING:
The Supreme Court denied the plaintiffs’ motion. It held that Act No. 1376 does not expressly prohibit a general denial in the answer. While Section 4 requires defendants to specifically deny the plaintiff’s ownership, right of administration, possession, or claim of title, it does not preclude them from denying other allegations in the complaint through a general or specific denial. The Court reasoned that judicial procedure inherently involves allegations and denials to frame issues for trial, and a special procedural law should not be construed to prohibit denials unless it contains a clear and unequivocal prohibition. Since at least one answer (the joint answer containing a general denial) was sufficient, the plaintiffs’ motion to strike all answers was denied. The Court also declined to rule on the constitutional challenge at that stage, directing that it be resolved during the trial on the merits. The motion of defendants Aglipay and the Municipality of Dingras was likewise denied.
Justice Tracey concurred in the result, expressing that while a general denial was not contemplated by the statute, specific denials and affirmative allegations in some answers were sufficient to raise issues for trial.