GR L 35000; (September, 1983) (Digest)
G.R. No. L-35000 September 30, 1983
SALUD YOUNG, plaintiff-appellee, vs. OLIVIA YOUNG, defendant-appellant.
FACTS
Salud Young filed a complaint against Olivia Young in the City Court of Cebu to recover the sum of P3,600. The complaint was based on written instruments, the substance of which was properly alleged, and copies were attached to the pleading. Olivia Young filed an answer, but she failed to specifically deny under oath the genuineness and due execution of these written documents upon which the action was founded.
The City Court of Cebu, noting this failure, rendered a judgment on the pleadings in favor of Salud Young. It ordered Olivia Young to pay the principal amount with interest, attorney’s fees, and costs. Olivia Young appealed to the Court of First Instance of Cebu, which affirmed the lower court’s judgment. The appeal was subsequently elevated to the Court of Appeals, which then certified the case to the Supreme Court, as it presented a pure question of law.
ISSUE
Whether the City Court of Cebu erred in rendering a judgment on the pleadings based on the defendant’s failure to enter a verified specific denial of the genuineness and due execution of the written instruments attached to the complaint.
RULING
The Supreme Court affirmed the lower courts’ decisions, holding that the judgment on the pleadings was correctly issued. The ruling is anchored on the procedural mandates of the Rules of Court. Under Section 7, Rule 8, when an action is founded upon a written instrument copied in or attached to the complaint, its genuineness and due execution are deemed admitted unless specifically denied under oath by the defendant.
The Court applied this rule strictly. Since the defendant-appellant, Olivia Young, did not file a verified answer specifically contesting the authenticity of the documents, she was deemed to have admitted them pursuant to Section 8, Rule 8. This implied admission removed any genuine issue of fact regarding the validity of the instruments upon which the monetary claim was based. Consequently, with no substantial factual issue to be tried, a judgment on the pleadings was the appropriate procedural recourse. The legal question was resolved purely on the application of these procedural rules, leading to the affirmation of the monetary judgment against the defendant-appellant.