G.R. No. 180088 - Japzon vs. Commission on Elections

Plaintiff Apolonio Galofa initiated a complaint for the recovery of possession and a quiet title over a parcel of land in Sta. Lourdes, Barcelona, Sorsogon.
The foundation of the complaint rested on the plaintiff’s assertion of prior ownership and possession by his late father, Francisco Galofa, with the title having been adjudicated to the plaintiff through an oral partition among co-heirs.

The complaint contained allegations that the plaintiff was unable to take actual possession of the property due to an adverse claim of ownership and possession asserted by the defendant Nee Bon Sing, or through his tenant/encargado, Abion Pantilone.
It was alleged that a certain Fe Nicolas had sold the property to the defendant, although the defendant was not entitled to legally sell, own, or dispose of the land, particularly given constitutional or other legal restrictions regarding aliens.
The plaintiff further contended that as a result of the defendant’s actions, he was forced to retain counsel—costing no less than P1,500.00 and incurring additional expenses of P500.00—which could have been avoided had the defendant acted fairly.

In his answer, the defendant denied the material averments contained in the complaint regarding the adverse claim of possession and title.
The defendant specifically stated that he had never asserted any title or possessory rights over the property and denied any responsibility for the legal fees incurred by the plaintiff.
Using language that was ambiguous—referred to as “negative pregnant”—the defendant qualified his denial; for instance, he denied having sufficient knowledge to form a belief regarding allegations of damages and other claims, thereby failing to clearly accept or refute the assertions.

On motion by the plaintiff that the defendant’s answer failed to tender a genuine issue, the lower court rendered judgment on the pleadings.
The court declared the plaintiff as the rightful owner of the property, free from any adverse claim or interest by the defendant, and ordered the defendant to deliver possession of the property.
The judgment also included an order for the defendant to pay attorney’s fees and costs.

The defendant later filed a motion for reconsideration and/or new trial, seeking to amend his answer and clarify his position.
Attached to the motion was the defendant’s affidavit reiterating his lack of any real right or interest in the property.
The motion was rejected by the lower court, and the judgment was accordingly affirmed on appeal.

Whether the defendant’s answer, particularly his use of “negative pregnant” language, tendered a genuine issue regarding the adverse claim of possession and title.
Whether the ambiguous depictions in the answer effectively amounted to an admission of the material allegations contained in the plaintiff’s complaint.

Whether the defendant was required to specifically deny the allegations relating to damages and the raising of a cloud on the plaintiff’s title, as alleged in certain paragraphs of the complaint.
Whether the general and ambiguous denials attributable to the “negative pregnant” nature were sufficient under the Rules of Court.

Whether it was proper for the lower court to render judgment on the pleadings based on the nature and clarity of the defendant’s responses.
Whether the plaintiff’s act of moving for judgment on the pleadings effectively barred further allegations (such as valid claims for damages) that were left undetermined by the defendant’s answer.