Case Digest (G.R. No. L-19762)
Facts:
- The case is Benavides v. Alabastro, G.R. No. L-19762, decided on December 23, 1964, by the Supreme Court of the Philippines.
- Adolfo B. Benavides (plaintiff-appellee) filed a lawsuit against Eduardo Alabastro (defendant-appellant) in the Court of First Instance of Manila.
- A judgment from the Municipal Court of Manila on August 26, 1955, ordered Alabastro to pay Ajax International Corporation P274.85, with 12% annual interest from January 25, 1955, plus 20% of the total as attorney's fees.
- Ajax International Corporation assigned its rights under this judgment to Benavides on January 6, 1961.
- Benavides notified Alabastro of this assignment on July 24, 1961, demanding payment totaling P438.73 as of June 20, 1961.
- Alabastro did not make the payment, leading Benavides to file a complaint on January 26, 1962, seeking the owed amount, interest, and attorney's fees.
- Alabastro denied the allegations and raised affirmative defenses in his response.
- On March 9, 1962, the trial court granted Benavides' motion for judgment on the pleadings, ordering Alabastro to pay.
- Alabastro appealed, contending that the court erred by deciding based solely on the pleadings.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of Alabastro, reversing the lower court's decision.
- The Court found that the trial court erred by issuing a judgment based solely on the pleadings, as the defendant's answer raised issues th...(Unlock)
Ratio:
- A judgment on the pleadings is valid only when no issues are raised or when all material allegations are admitted by the opposing party.
- Alabastro's answer included denials and affirmative defenses, which presented clear issues.
- The Court referenced Section 10, Rule 8 of the Rules of Court, stating that a denial based on lack of knowledge or information is sufficient to raise an issue.
- The rul...continue reading
Case Digest (G.R. No. L-19762)
Facts:
The case of Benavides v. Alabastro, G.R. No. L-19762, was decided by the Supreme Court of the Philippines on December 23, 1964. The plaintiff-appellee, Adolfo B. Benavides, initiated legal action against the defendant-appellant, Eduardo Alabastro, in the Court of First Instance of Manila. The background of the case dates back to a judgment rendered by the Municipal Court of Manila on August 26, 1955, which ordered Alabastro to pay Ajax International Corporation the sum of P274.85, with interest accruing at 12% per annum from January 25, 1955, as well as 20% of the total amount as attorney's fees. On January 6, 1961, Ajax International Corporation assigned its rights under this judgment to Benavides, who subsequently notified Alabastro of this assignment on July 24, 1961. Following this notification, Benavides demanded payment from Alabastro, which totaled P438.73 as of June 20, 1961. When Alabastro failed to comply with the payment demand, Benavides filed a complaint on January 26, 1962, seeking to recover the owed amount along with interest and attorney's fees. In his answer, Alabastro denied the material allegations of the complaint and asserted various affirmative defenses. On March 9, 1962, the trial court granted Be...