Case Digest (G.R. No. L-23426)
Facts:
- Plaintiffs: Leopoldo Sy-Quia, Hector Moreno, Alejandro de Santos, Pedro Aguirre, and Hans Inhelder.
- Defendants: Mary Marsman, A.L. Velilla, A.V. Santiago, E.G. Vito, and H.A. Doornbosch.
- Residency: Plaintiffs and defendants were residents of Rizal, except for Sy-Quia and Doornbosch, who resided in Manila.
- Corporation: Marsman Investments, Ltd. (organized under UK law, with offices in London and Makati, Rizal).
- December 29, 1960: Plaintiffs were elected directors at the annual and extraordinary general meetings.
- January 4, 1961: Plaintiffs held an organizational meeting and demanded turnover of offices and records from defendants.
- Defendants' Response: Refused to comply; plaintiffs filed a complaint in the Court of First Instance (CFI) of Rizal.
- Defendants' Defense: General denials and motion to dismiss citing pending actions involving the same parties/issues.
- CFI Ruling: Denied motion to dismiss; ruled in favor of plaintiffs, declaring them duly elected directors and ordering turnover of records.
- Appeal: Defendants appealed the decision.
Issue:
- (Unlock)
Ruling:
- No, the defendants' general denials did not constitute a valid defense under the Rules of Court. ...(Unlock)
Ratio:
- Defendants' Answer: Consisted of general denials, failing to meet specific denial requirements under the Rules of Court.
- Specific Denials Requirement: Section 10 of the Revised Rules of Court mandates specific denials with substance to support them.
- Defendants' Failure: Failed to specify which allegations they were denying (e.g., annual meeting, election of plaintiffs, compliance with British laws).
- General Denials: Operated as admissions of the facts pleaded by the plaintiffs.
- Plea of Lack of Knowledge: Deemed insincere and made in bad faith (e.g., denial of presence at Marsman Building on January 4, 1961).
- Defendants' Strategy: To confuse and delay plaintiffs, violating the policy...continue reading
Case Digest (G.R. No. L-23426)
Facts:
The case involves a quo warranto proceeding initiated by plaintiffs Leopoldo Sy-Quia, Hector Moreno, Alejandro de Santos, Pedro Aguirre, and Hans Inhelder against defendants Mary Marsman, A.L. Velilla, A.V. Santiago, E.G. Vito, and H.A. Doornbosch. The plaintiffs and defendants were all residents of Rizal, except for Sy-Quia and Doornbosch, who resided in Manila. Prior to December 29, 1960, the defendants constituted the Board of Directors of Marsman Investments, Ltd., a corporation organized under the laws of the United Kingdom with principal offices in London and Philippine offices in Makati, Rizal. On December 29, 1960, at the annual general meeting and extraordinary general meeting of stockholders held at the corporation's Philippine offices, the plaintiffs were duly elected as directors of Marsman Investments, Ltd. On January 4, 1961, the plaintiffs held an organizational meeting and demanded the turnover of the offices and corporate records from the defendants, who refused. Consequently, the plaintiffs filed a complaint in the Court of First Instance (CFI) of Rizal for the ouster of the defendants and their recognition as the lawful directors. The defendants responded with general denials and moved for dismissal, citing pending actions involving the same parties and issues. The CFI denied the motion to dismiss and late...