“If the filing of the judgment on the pleadings is proper, the court can proceed to render judgment without a trial after an Answer is filed by the defendant”
An action is commenced by filing a complaint in court and paying the filing fees assessed by the clerk of court. The complaint is the pleading that asserts the complainant or plaintiff’s claims or causes of action (Rule 6, Section 3, 2019 Rules of Civil Procedure).
A cause of action is the act or omission by which a party violates or breaches the rights of another (Rule 2, Section 2). Hence, the complainant comes to court to seek redress for a wrong or to recover certain damages he or she may have suffered by reason of the breach.
The complaint usually contains allegations in support of the plaintiff’s claims and the reliefs sought by him or her from the court.
The person sued (the defendant), after proper service of summons and the complaint, will have to file an Answer within 30 days from the receipt thereof (Rule 11, Section 11).
The Answer is a pleading that sets forth the defendant’s defenses. The defenses may either be negative or affirmative. A negative defense is the specific denial of the material fact or facts alleged in the pleading of the claimant to defeat the latter’s cause or causes of action (Rule 6, Section 5).
The negative defense must be categorical, supported by material facts and evidence.”[W]hen defendant’s answer denies the allegations of the complaint because the defendant ‘has no knowledge or information sufficient to form a belief’ and ‘specifically denies’ other allegations, … said denials are in fact mere general denials amounting to admissions of the material allegations of the complaint” (J. P. Juan and Sons v. Lianga Industries, G.R. No. L-25137, July 28, 1969).
This is different from an affirmative defense, which contains an allegation of a new matter which, while hypothetically admitting the material allegations in the pleading of the claimant, would nevertheless prevent or bar the plaintiff’s recovery.
Affirmative defenses include fraud, statutes of limitations or prescription, payment, illegality, and estoppel, among others (Rule 6, Section 5).
In simpler words, an affirmative defense admits the material facts that lays down the claim or cause of action but renders the plaintiff unable to recover, the reason being that there exists legal defenses or factual circumstances that preclude recovery on the part of the plaintiff, such as a lack of subject matter jurisdiction, improper venue, or fraud.
In one case, it was established that on October 15, 1962, the defendant purchased office equipment from the plaintiff listed in Purchase Order 001/62, payable in 30 days.
The equipment delivered to the defendant had a total selling price of P1,890.00, for which the latter paid only P990.00, leaving an unpaid balance of P900.00. Despite repeated demands, the defendant failed and refused to pay the outstanding balance of P900.00 (G.R. No. L-25137, July 28, 1969).
The Supreme Court, finding no error in the trial court’s decision granting a judgment on the pleadings, held that “[T]he facts alleged in the plaintiff’s complaint are of the kind that plainly and necessarily must be within the defendant’s knowledge, and of which the defendant cannot logically pretend ignorance, …” and that “[T]he material allegations of the complaint must, therefore, be deemed as admitted by the defendant …” (G.R. No. L-25137, July 28, 1969).
Furthermore, the defendant has no cause to complain against the judgment appealed.
His claim that it tendered an issue with his “affirmative defense” of “having no obligation to pay to the plaintiff the amount or sum of money claimed in the complaint” was correctly held by the Court to be a mere conclusion and not premised on an allegation of material facts (G.R. No. L-25137, July 28, 1969).
In another case, Sannaedle sued Asian Construction to recover the balance of US$615,620.33 from a principal amount of US$3,745,287.94, which represents the cost of supplying and erecting insulated panel systems at the Philippine Centennial Exposition Theme Park.
Sannaedle made several written demands for Asian Construction to pay; however these were not heeded by the latter (Asian Construction v. Sannaedle Co., G.R. No. 181676, June 11, 2014).
After Asian Construction filed its Answer, Sannaedle moved for judgment on the pleadings on the grounds that the Answer admitted all material allegations of the Complaint and, therefore, failed to tender an issue.
In effect, Sannaedle deemed that Asian Construction’s Answer admitted the existence of the Memorandum of Agreement and its failure to pay the balance (G.R. No. 181676, June 11, 2014).
In sustaining the trial court’s decision, granting the motion for judgment on the pleadings, and ordering the payment of the sum of US$615,620.33, the appellate courts stated “that the express terms of the Memorandum of Agreement, the genuineness and due execution of which are not denied by the [Asian Construction]… [and Sannaedle] has sufficiently shown by the allegations of the Complaint and the Answer that the [Asian Construction] is clearly liable for the payment thereof” (G.R. No. 181676, June 11, 2014).
What is judgment on the pleadings? This occurs when an answer fails to tender an issue, or otherwise admits the material allegations of the adverse party’s pleading (Rule 34, Section 1).
An answer fails to tender an issue if it fails to specifically deny the material allegations consistent with Section 10, Rule 8 of the 2019 Rules of Civil Procedure, resulting in the adverse party’s admission.
If the filing of the judgment on the pleadings is proper, the court can proceed to render judgment without a trial after an Answer is filed by the defendant.
Under the 2019 Amendments of the Rules of Civil Procedure, the court may, in its own initiative, render judgment on the pleadings without need of a motion filed by the claimant. The same Rule retained the claimant’s prerogative to file a motion.
The shift in the policy of the Supreme Court in dealing with judgment on the pleadings was made more evident in the 2019 Amendments of the Rules of Civil Procedure, when the trial courts were given the power, if the grounds are present, to include “in the pre-trial order that the case be submitted for summary judgment or judgment on the pleadings” (Rule 18, Section 10).