Facts:

This case, Trinidad L. Aurelio vs. Maximo Baquiran, was decided by the Supreme Court of the Philippines on October 31, 1956, with G.R. No. L-9316. The dispute arose from a verified complaint filed by Trinidad L. Aurelio (the plaintiff) against Maximo Baquiran (the defendant) in the Court of First Instance of Ilocos Norte. Aurelio alleged that from June 1 to September 30, 1950, Baquiran borrowed various sums of money from him, ultimately amounting to P6,288, as acknowledged by Baquiran in a document referred to as Exhibit A. Aurelio claimed that Baquiran initially paid only P50 towards this debt and had failed to remit the remaining balance despite repeated demands for payment. Aurelio further asserted that Baquiran was disposing of his properties with the intent to defraud his creditors, which led him to seek a writ of attachment against the defendant’s assets. The lower court granted this writ.

In his defense, Baquiran denied the valid execution of Exhibit A, stating that he n

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Facts:

Background of the Case

• Trinidad L. Aurelio (plaintiff and appellee) filed a verified complaint against Maximo Baquiran (defendant and appellant), seeking the payment of money allegedly borrowed.
• The complaint asserted that from 1 June to 30 September 1950, the defendant borrowed various sums of money, which, upon liquidation, amounted to P6,288.
• It was further alleged that the defendant paid only P50 on account and subsequently failed to settle the balance despite repeated demands.
• The plaintiff claimed that the defendant, in anticipation of defrauding creditors, had disposed of or was about to dispose of his property, which led to the plaintiff’s request for a writ of attachment.
• The writ of attachment, as prayed for by the plaintiff, was duly granted by the trial court.

Admissions and Denials in the Pleadings

• The defendant, in his answer, under oath, denied the genuineness and due execution of Exhibit A attached to the complaint.
• The defendant denied having borrowed any sum of money from the plaintiff.
• He acknowledged having paid P50 to the plaintiff but contended that the sum of P6,288 was received as partial payment for a P10,000 contribution towards a partnership that both parties had organized for engaging in the construction business.
• The defendant further alleged that Exhibit A did not reflect the true intent of the parties; it was executed solely to placate the plaintiff by demonstrating his supposed investment to his wife and father.

Counterclaim by the Defendant

• The defendant set up a counterclaim seeking P3,712—the unpaid balance of the alleged P10,000 contribution—to the partnership.
• Additionally, he sought P5,000 as damages for the alleged harm caused by the issuance of the writ of attachment and for what he described as the malicious filing of an unfounded complaint.
• In response, the plaintiff asserted that the amount claimed by the defendant was in fact money borrowed from him as well as the salary and bonus earned by the defendant from 1 June to 30 September 1950 while acting as supervising engineer in the defendant’s construction business.

Court Proceedings and Motions

• On 12 September 1952, the defendant moved for judgment on the pleadings and for the dismissal of the plaintiff’s complaint on the ground that the complaint did not state a cause of action.
• The defendant argued that Exhibit A, which purportedly acknowledged his indebtedness, was defective because it contained no fixed period or term for repayment, thus necessitating the fixing of a payment period by the Court pursuant to Article 1197 of the New Civil Code.
• On 17 December 1952, the plaintiff filed a pleading, agreeing to the defendant’s prayer for judgment on the pleadings but objecting to the motion to dismiss.
• On 18 December 1952, the trial court denied the defendant’s motion to dismiss and granted the motion for judgment on the pleadings, ordering the defendant to pay P6,238 with legal interest at six percent per annum from the filing of the complaint until fully paid, along with costs.

Grounds for Judgment on the Pleadings

• The trial court’s judgment rested on the proposition that one who moves for judgment on the pleadings without proving the truth of his own allegations must be deemed to admit the material and relevant allegations of the opposing party.
• It held that the defendant’s verified answer tendered an issue, and thus his subsequent motion for judgment on the pleadings was questionable given that it effectively conceded the material allegations of the complaint.

Issue:

Appropriateness of the Motion for Judgment on the Pleadings

• Whether the defendant’s verified answer, which expressly tendered an issue, precluded him from subsequently moving for judgment on the pleadings.
• Whether the defendant’s motion for judgment on the pleadings was proper when his answer did not admit the material allegations of the plaintiff’s complaint.

Sufficiency and Interpretation of the Acknowledgment Document (Exhibit A)

• Whether Exhibit A, which purported to be an acknowledgment of indebtedness, was sufficient to establish a debt due to its failure to fix a definite period for repayment.
• Whether the partial payment of P50 authenticated the signature and the obligation alleged in Exhibit A.
• Whether the document was executed merely as a facade to facilitate the plaintiff’s ulterior motives (i.e., to show a semblance of investment in the partnership).

Proper Remedy and Relief

• Whether the relief granted by the trial court ordering the defendant to pay P6,238, with interest, was consistent with the pleadings and the applicable rules governing judgment on the pleadings.
• Whether the defendant’s counterclaim for an allegedly unpaid balance and damages should be adjudicated separately rather than being resolved through a judgment on the pleadings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)