Facts:

In the case of Maria Baetamo v. Hon. Amado P. Amador, et al., the petitioner, Maria Baetamo, was the special administratrix of the intestate estate of her deceased relative, Geronima Baetamo y Gonzales. The case revolved around three civil actions instituted by Baetamo at the Court of First Instance of Manila against Leon M. Samson, the surviving husband of the deceased, and his corespondents. The events unfolded as follows: Maria filed the first two actions (Cases Nos. 2274 and 2275) to annul purported sales conducted by Samson of certain parcels of land claimed to belong to the conjugal partnership existing between him and Geronima. The basis for annulment was the assertion that such sales were fictitious and intended to defraud the heirs. The third action (Case No. 2291) aimed to prevent Samson from further selling remaining properties belonging to the conjugal partnership, alleging an intention to defraud the heirs.

In May 1944, the defendants filed answers to the complaint

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Facts:

Parties and Background

• The case is identified as 74 Phil. 735, G.R. No. 49255, decided on September 18, 1944.
• Petitioner: Maria Baetamo, acting in her capacity as the special administratrix of the intestacy of the deceased Geronima Baetamo y Gonzales.
• Respondents:
• Leon M. Samson, the surviving husband of the deceased, alleged to have sold properties.
• His individual co-respondents and Hon. Amado P. Amador, Judge of the Court of First Instance of Manila.
• Subject Matter:
• Dispute over certain parcels of land and other properties allegedly forming part of the conjugal partnership between Samson and the deceased.
• Allegations that the properties were disposed of in a fraudulent manner aimed at defrauding the heirs of the deceased.

Nature of the Litigation

• Consolidated Civil Actions:
• Two actions (Cases Nos. 2274 and 2275) filed to annul the sale of some parcels of land.
• A third action (Case No. 2291) filed to prevent further disposition of the remaining properties.
• Grounds for the Actions:
• The sales were claimed to be fictitious and executed with the sole purpose of defrauding the deceased’s heirs.
• The petitioner sought to protect the interests of the estate by challenging these transactions.

Procedural History

• Filing of Answers:
• In May 1944, the respondent Leon M. Samson and his co-respondents filed answers to the complaints.
• The answers contained a text identical denial stating:
• A specific denial of every allegation contained in each paragraph of the complaint.
• A reserved right to file an amended answer containing additional special affirmative defenses and counterclaims appropriate to the case.
• Consolidation and Pretrial Developments:
• In June 1944, the three cases were consolidated for trial by the respondent judge upon the petitioner's motion.
• On July 4, 1944, the petitioner filed a motion requesting judgment on the pleadings, contending that the defendants’ answers, being mere general denials, did not create the proper issue and effectively amounted to an admission of the complaint’s material allegations.
• In support of the petition, the petitioner invoked the decision in El Hogar Filipino vs. Santos Investments, Inc. to argue that the reservation to amend was without effect.

Lower Court Order

• On July 19, 1944, the respondent judge rendered an order denying the petitioner’s motion for judgment on the pleadings.
• Main points in the order:
• The order emphasized that the defendant(s) had filed answers which denied “each and every allegation” but also reserved the right to later amend and introduce special defenses and counterclaims—thereby distinguishing this case from El Hogar Filipino which featured a simple general denial.
• The judge noted that all pleadings should be liberally construed to do substantial justice, leading to the denial of the motion for judgment on the pleadings.
• As a result, the petitioner subsequently instituted a petition for certiorari and mandamus to set aside the order and compel the respondent judge to render judgment on the pleadings.

Core Issues Raised in the Pleadings

• Whether the nature of the answers—despite the use of the term “specifically”—amounted only to a general denial.
• Whether the reservation to file a subsequent amended answer was legally valid and effective under the Rules of Court, particularly given the time limits established for such amendments.

Issue:

Nature of the Denial

• Whether the respondents’ answers, which contained the phrase “denies specifically each and every allegation,” constitute a general denial or a proper specific denial required under the Rules of Court.
• The distinction between a general denial and a specific denial in the context of pleading requirements under Sections 6, 7, and 8 of Rule 9 of the Rules of Court.

Reservation to File an Amended Answer

• Does the defendants’ reservation of the right to later file an amended answer effectually allow them to qualify or change their initial denial?
• Whether such a reservation is legally acceptable under the procedural rules, especially given that any amendment must adhere to the strict time limits provided under Section 1 of Rule 17.

Timeliness and Judicial Efficiency

• Whether the defendants’ failure to timely file an amended answer (within ten days after service, as required by Rule 17) renders their reservation ineffective.
• The consequential impact of the procedural default on the validity of the defendants’ answers and the petitioner’s motion for judgment on the pleadings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)