Title
Sy-Quia vs. Marsman
Case
G.R. No. L-23426
Decision Date
Mar 1, 1968
In a quo warranto proceeding, the court rules in favor of the plaintiffs, declaring them as the duly elected directors of Marsman Investments, Ltd., and orders the defendants to turn over all company records, as their answer consisting of general denials was deemed insufficient to tender an issue.
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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:

  1. No, the defendants' general denials did not constitute a valid defense under the Rules of Court.
  2. ...(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

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