Monday, March 20, 2017

Fernando Medical Enterprises, Inc. vs. Wesleyan University Philippines, Inc. Case Digest

Fernando Medical Enterprises, Inc. vs. Wesleyan University Philippines, Inc. 
G.R. No. 207970. January 20, 2016


BERSAMIN, J.:

Doctrine:
The trial court may render a judgment on the pleadings upon motion of the claiming party when the defending party's answer fails to tender an issue, or otherwise admits the material allegations of the adverse party's pleading. For that purpose, only the pleadings of the parties in the action are considered. It is error for the trial court to deny the motion for judgment on the pleadings because the defending party's pleading in another case supposedly tendered an issue of fact.

Facts:
From January 9, 2006 until February 2, 2007, the petitioner, a domestic corporation dealing with medical equipment and supplies, delivered to and installed medical equipment and supplies at the respondent's hospital. According to the petitioner, the respondent paid only P67,3 57,683.23 of its total obligation of P123,901,650.00, leaving unpaid the sum of P54,654,195.54.

However, on February 11, 2009, the petitioner and the respondent entered into an agreement whereby the former agreed to reduce its claim to only P50,400,000.00, and allowed the latter to pay the adjusted obligation on installment basis within 36 months.

In the letter dated May 27, 2009, the respondent notified the petitioner that its new administration had reviewed their contracts and had found the contracts defective and rescissible due to economic prejudice or lesion; and that it was consequently declining to recognize the February 11, 2009 agreement because of the lack of approval by its Board of Trustees and for having been signed by Maglaya whose term of office had expired.

On June 24, 2009, the petitioner sent a demand letter to the respondent. Due to the respondent's failure to pay as demanded, the petitioner filed its complaint for sum of money in the RTC.

The respondent moved to dismiss the complaint upon the following grounds, namely: (a) lack of jurisdiction over the person of the defendant; (b) improper venue; (c) litis pendentia; and (d) forum shopping. In support of the ground of litis pendentia, it stated that it had earlier filed a complaint for the rescission of the four contracts and of the February 11, 2009 agreement in the RTC in Cabanatuan City; and that the resolution of that case would be determinative of the petitioner's action for collection.

After the RTC denied the motion to dismiss on July 19, 2009, the respondent filed its answer. On September 28, 2011, the petitioner filed its Motion for Judgment Based on the Pleadings, stating that the respondent had admitted the material allegations of its complaint and thus did not tender any issue as to such allegations. The respondent opposed the Motion for Judgment Based on the Pleadings, arguing that it had specifically denied the material allegations in the complaint.

Judgment of the RTC
At the hearing, the court issued an Order denying the Motion for Judgment Based on the Pleadings considering that the allegations stated on the Motion are evidentiary in nature. The Court, instead of acting on the same, sets the case for pre-trial, considering that with the Answer and the Reply, issues have been joined.



Judgment of the CA
On July 2, 2013, the CA promulgated its decision. Although observing that the respondent had admitted the contracts as well as the February 11, 2009 agreement, the CA ruled that a judgment on the pleadings would be improper because the outstanding balance due to the petitioner remained to be an issue in the face of the allegations of the respondent in its complaint for rescission in the RTC in Cabanatuan City.


Issue:
Whether the Court of Appeals erred in going outside of the respondent's answer by relying on the allegations contained in the latter's complaint for rescission.

Ruling of the SC:
Yes, the Court of Appeals erred in going outside of the respondent's answer by relying on the allegations contained in the latter's complaint for rescission. In order to resolve the petitioner's Motion for Judgment Based on the Pleadings, the trial court could rely only on the answer of the respondent filed in Civil Case No. 09-122116. Under Section 1, Rule 34 of the Rules of Court, the answer was the sole basis for ascertaining whether the complaint's material allegations were admitted or properly denied. As such, the respondent's averment of payment of the total of P78,401,650.00 to the petitioner made in its complaint for rescission had no relevance to the resolution of the Motion for Judgment Based on the Pleadings. The CA thus wrongly held that a factual issue on the total liability of the respondent remained to be settled through trial on the merits. It should have openly wondered why the respondent's answer in Civil Case No. 09-122116 did not allege the supposed payment of the P78,401,650.00, if the payment was true, if only to buttress the specific denial of its alleged liability. The omission exposed the respondent's denial of liability as insincere.


WHEREFORE, the Court REVERSES and SETS ASIDE the decision promulgated on July 2, 2013; DIRECTS the Regional Trial Court, Branch 1, in Manila to resume its proceedings in Civil Case No. 09-122116 entitled Fernando Medical Enterprises, Inc. v. Wesleyan University-Philippines, and to forthwith act on and grant the Motion for Judgment Based on the Pleadings by rendering the proper judgment on the pleadings; and ORDERS the respondent to pay the costs of suit.



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