Case Summary (G.R. No. 144018)
Key Dates and Transactions
• January 9, 2006 – Memorandum of Agreement for medical equipment, ₱18,625,000.00
• July 5, 2006 – Deed of Undertaking for medical gas pipeline, ₱8,500,000.00
• July 27, 2006 – Deed of Undertaking for CT and CV-P units, ₱65,000,000.00
• February 2, 2007 – Deed of Undertaking for furnishings and equipment, ₱32,926,650.00
Total contractual obligation: ₱123,901,650.00; payments made: ₱67,357,683.23; unpaid balance: ₱54,654,195.54.
February 11, 2009 Compromise Agreement
Parties agreed to reduce the claim to ₱50,400,000.00, payable in 36 monthly installments of ₱1,400,000.00 via post-dated checks.
Disavowal of Contracts and Agreement
May 27, 2009 letter: respondent’s new administration challenged the four contracts as rescissible for economic lesion, denied board approval and authority of signatory for the February 11, 2009 agreement, and refused to honor the settlement.
Complaint, Motion to Dismiss, and Answer in the RTC
• Petitioner filed a complaint for sum of money in the RTC, Manila (Civil Case No. 09-122116).
• Respondent’s motion to dismiss: lack of jurisdiction, improper venue, litis pendentia, and forum shopping – denied July 19, 2009.
• Answer (ad cautelam): admitted paragraphs 2–5, 9–10; denied paragraphs 6–8 (for lack of knowledge), and 11–12 (as conclusions of law).
Motion for Judgment on the Pleadings and RTC Ruling
September 28, 2011: petitioner moved for judgment on the pleadings under Section 1, Rule 34, Rules of Court, asserting that respondent’s answer failed to tender issues on material allegations.
October 27, 2011 Order: RTC set case for pre-trial, denying the motion for judgment on the pleadings. Reconsideration denied December 29, 2011.
Court of Appeals Decision
July 2, 2013: CA affirmed. It held that:
- Respondent’s admissions of the contracts and performance were subject to “special and affirmative defenses” (previously rejected).
- Despite admissions, a factual issue remained on the balance due because respondent’s separate complaint for rescission in Cabanatuan alleged a different total payment (₱78,401,650.00).
Issue before the Supreme Court
Did the CA err in considering pleadings from another case to find a factual issue and thus uphold the denial of the motion for judgment on the pleadings?
Rule on Judgment on the Pleadings
Under Section 1, Rule 34, Rules of Court (1987 Constitution): a party is entitled to judgment on the pleadings when the opposing answer fails to tender an issue or admits all material allegations. Issue generation depends solely on the answer’s treatment of ultimate facts, governed by Section 10, Rule 8 (specific, partial, or knowledge-based denials).
Analysis of Admissions and Denials
• Respondent expressly admitted the existence, performance and balance of the contracts, and execution of the February 11, 2009 agreement.
• Denials of paragraphs 6–8 on th
Case Syllabus (G.R. No. 144018)
Facts and Contracts
- From January 9, 2006 to February 2, 2007, petitioner delivered and installed medical equipment and supplies under four agreements with respondent:
- Memorandum of Agreement (January 9, 2006) for equipment worth ₱18,625,000.
- Deed of Undertaking (July 5, 2006) for medical gas pipeline system valued at ₱8,500,000.
- Deed of Undertaking (July 27, 2006) for Diamond Select Slice CT and CV-P equipment costing ₱65,000,000.
- Deed of Undertaking (February 2, 2007) for hospital furnishings and equipment worth ₱32,926,650.
- Total contractual obligation: ₱123,901,650.00.
- Respondent paid ₱67,357,683.23, leaving an unpaid balance of ₱54,654,195.54.
Compromise Agreement of February 11, 2009
- Petitioner agreed to reduce its claim to ₱50,400,000.00.
- Respondent to pay in thirty-six monthly instalments of ₱1,400,000.00 via postdated checks.
- Four checks (total ₱5,600,000.00) were honored; the rest were dishonored, rendering the entire amount immediately due.
Respondent’s Rescission Claim and Demand Letters
- May 27, 2009 letter: respondent’s new administration declared the four original contracts rescissible for lesion and economic prejudice, disavowed the February 11, 2009 agreement for lack of board approval and expired agent authority.
- June 24, 2009 demand letter: petitioner demanded payment of either the adjusted ₱50,400,000 obligation or the original ₱54,654,195.54 within ten days.
RTC Proceedings in Civil Case No. 09-122116
- Petitioner filed complaint for sum of money in RTC Manila.
- Respondent moved to dismiss for lack of personal jurisdiction, improper venue, litis pendentia and forum shopping—motion denied on July 19, 2009.
- Respondent’s answer (ad cautelam):
- Admitted paragraphs 2–5 and 9–10 (existence of contracts, total obligation, payments, balance due, February 11 agreement).
- Denied paragraphs