Case Digest (G.R. No. 60783)
Facts:
- The case Gaw v. Court of Appeals (G.R. No. 60783) involves a conflict between Worldwide Philippines Marketing Corporation (WPMC) and Joaquin S. Gaw.
- WPMC initiated a complaint on February 2, 1981, in the Court of First Instance of Manila, Branch XI, seeking monetary damages and preliminary attachment.
- The complaint underwent two amendments, with the final one submitted on May 22, 1981.
- WPMC accused Gaw of encashing personal and postdated checks amounting to ₱315,332.00 from August 1980 to January 1981.
- Gaw responded on July 29, 1981, denying the allegations and asserting payment for one of the checks.
- WPMC filed a motion for partial judgment on the pleadings, claiming Gaw admitted the checks' genuineness by not specifically denying them under oath.
- Gaw opposed the motion, stating the checks did not belong to him and that he had settled the loan related to one check.
- On September 16, 1981, the trial court issued a partial judgment against Gaw, initially ordering him to pay ₱140,000.00, which was later reduced to ₱100,000.00 on October 27, 1981.
- Following a fire that destroyed court records, WPMC sought a writ of execution, which was granted despite Gaw's objections.
- Gaw filed a petition for certiorari and requested a writ of preliminary injunction, which the Court of Appeals dismissed on May 7, 1982, prompting an appeal to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of Joaquin S. Gaw, reversing the decisions of both the Court of Appeals and the lower court.
- The Court found that the lower court abused its discretion by granting judgment on the plead...(Unlock)
Ratio:
- The ruling was grounded in principles of due process and the correct application of the Rules of Court concerning judgments on pleadings.
- The Court highlighted that the lower court's decision was oppressive and constituted grave abuse of discretion, as it issued a judgment without a hearing, where factual disputes required resolution through evidence.
- Gaw's response raised legitimate issues by disputing the allegations regarding the checks, especially since WPMC's complaint did not assert that Gaw's signature was on the checks.
- The Court referenced Section 8, Rule 8 of the Rules of Court, which al...continue reading
Case Digest (G.R. No. 60783)
Facts:
The case of Gaw v. Court of Appeals (G.R. No. 60783) involves a legal conflict initiated by Worldwide Philippines Marketing Corporation (WPMC) against Joaquin S. Gaw. The legal proceedings began on February 2, 1981, when WPMC filed a complaint in the Court of First Instance of Manila, Branch XI, seeking monetary damages and preliminary attachment. The complaint underwent two amendments, with the final one submitted on May 22, 1981. WPMC accused Gaw of encashing several personal and postdated checks amounting to ₱315,332.00 between August 1980 and January 1981. In response, Gaw filed an answer with a counterclaim on July 29, 1981, denying the allegations and asserting defenses, including a claim of payment for one of the checks. The case was scheduled for a pre-trial hearing; however, WPMC filed a motion for partial judgment on the pleadings, contending that Gaw had admitted the genuineness of the checks by failing to specifically deny them under oath. Gaw opposed this motion, insisting that the checks did not belong to him and that he had settled the loan related to one of the checks. On September 16, 1981, the trial court issued a partial judgment against Gaw, initially ordering him to pay ₱140,000.00, which was later reduced to ₱100,000.00 on October 27, 1981. Following a fire that destroyed court records, WPMC sought a writ of execution, which was granted despite Gaw's objections. Gaw subsequently filed a petition for certiorari with a request for a writ of preli...