Case Digest (G.R. No. 1403)
Facts:
The case of Jose E. Alemany et al. vs. John C. Sweeney was decided by the Supreme Court of the Philippines on December 29, 1903. The petitioners, Jose E. Alemany and others, filed an original action against John C. Sweeney, who was the Judge of the Court of First Instance of Manila. The case arose after the defendant, Sweeney, had overruled a demurrer to the complaint, prompting the defendant to file an answer. The plaintiffs subsequently moved to strike out this answer on the grounds that it neither admitted nor denied the allegations set forth in the complaint, nor did it introduce any new facts. Upon examination, the Supreme Court found that the answer primarily discussed legal questions and did not address the factual allegations of the complaint. According to Section 94 of the Code of Civil Procedure, any material allegation in the complaint that is not explicitly denied in the answer is deemed admitted. The Court noted that the answer, by failing to deny the...
Case Digest (G.R. No. 1403)
Facts:
- Case Background: This is an original action filed in the Supreme Court. The petitioners, Jose E. Alemany et al., filed a complaint against John C. Sweeney, the Judge of the Court of First Instance of Manila.
- Procedural History: A demurrer to the complaint was previously overruled, and the defendant filed an answer. The plaintiffs moved to strike out the defendant's answer, arguing that it neither admitted nor denied the facts set out in the complaint nor alleged any new facts.
- Content of the Answer: The defendant's answer did not specifically deny any material allegations in the complaint. Instead, it primarily discussed legal questions without addressing the factual allegations.
- Legal Provision Cited: Section 94 of the Code of Civil Procedure states that a material allegation in the complaint not denied in the answer is deemed admitted.
Issue:
- Whether the defendant's answer, which neither admits nor denies the facts in the complaint but instead discusses legal arguments, is valid.
- Whether the plaintiffs' motion to strike out the entire answer should be granted.
Ruling:
The Supreme Court denied the plaintiffs' motion to strike out the defendant's answer. The Court held that the answer, by failing to deny the material allegations of the complaint, was deemed to have admitted those facts under Section 94 of the Code of Civil Procedure. Such a tacit admission is equivalent to an express admission. The Court also noted that the plaintiffs could have demurred to the answer under Section 99 but found it more expeditious to proceed to trial on the merits.
Ratio:
- Tacit Admission of Facts: Under Section 94 of the Code of Civil Procedure, a material allegation in the complaint that is neither generally nor specifically denied in the answer is deemed admitted. The defendant's answer, by not denying the facts, constituted a tacit admission of those facts.
- Relevance of the Answer: An answer that admits the facts in the complaint is relevant to the case and cannot be stricken out as irrelevant under Section 107 of the Code of Civil Procedure.
- Expediency in Litigation: The Court emphasized that when an answer fails to state a defense, the most efficient course of action is to proceed to trial on the merits, where the only issue would be whether the plaintiff is entitled to judgment based on the admitted facts.