Case Summary (G.R. No. L-22018)
Complaint and Defendant's Response
Galofa's complaint asserted that Nee Bon Sing had made an unwarranted claim to ownership of the property, which was legally impossible given the latter's status as an alien under Philippine law. The plaintiff also included a claim for attorney’s fees incurred due to the defendant's actions. In his answer, the defendant denied the essential allegations of ownership and stated that he never claimed possessory rights over the land.
Judgment on the Pleadings
The plaintiff moved for judgment on the pleadings, arguing that the defendant's response did not introduce a genuine issue of fact. The lower court ruled in favor of Galofa, recognizing him as the rightful owner of the property free from any claims by the defendant and ordering Bon Sing to provide possession and pay attorney's fees.
Analysis of the Court’s Decision
The court did not identify any reversible error in the lower court's decision. The defendant's denial of Galofa’s allegations constituted a "negative pregnant," indicating some admission of facts, thus validating the plaintiff’s position. The court underscored that a denial that includes qualifications suggests the material assertion is accepted, while only the qualification is denied.
Defendant's Denial of Liability
With respect to Galofa’s assertion regarding attorney's fees, the defendant only denied liability, which does not negate the underlying fact of hiring counsel. Thus, the court appropriately processed the matter as judgment on the pleadings, given that the defendant's denials concerning the attorney's fees did not create a triable issue.
Examination of the Specific Denials
The court analyzed the specific denials made by Bon Sing about the claims of damages, recognizing that the defendant's efforts to deny certain allegations regarding damages were extraneous and ineffective, as they did not create valid disputes. The judgment correctly focused on the plaintiff's assertions that were unchallenged.
Rejection of Motion for Reconsideration
Bon Sing's motions
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Case Background
- The case revolves around a direct appeal from a judgment on the pleadings in Civil Case No. 145 (Ni. 1737-Sorsogon) of the Court of First Instance of Sorsogon.
- The primary issue is whether the defendant's answer to the complaint presented a genuine issue.
Parties Involved
- Plaintiff-Appellee: Apolonio Galofa, who claims ownership of a parcel of land in Sta. Lourdes, Barcelona, Sorsogon, based on prior ownership by his late father, Francisco Galofa.
- Defendant-Appellant: Nee Bon Sing, who allegedly claimed rights over the same property through a supposed sale by a third party, Fe Nicolas.
Plaintiff's Allegations
- The plaintiff asserts that he is the rightful owner of the land due to its adjudication in an oral partition among his co-heirs.
- He alleges that his possession has been hindered by the defendant's adverse claim of ownership.
- The complaint states that the defendant, as an alien, is prohibited from owning real property under the Constitution.
Defendant's Response
- The defendant denies the material claims made in the plaintiff's complaint, particularly regarding his assertion of ownership or possession.
- His answer indicates that he does not claim any possessory rights over the property nor has he made any conveyance claims based on a sale by