G.R. No. 176570 : July 18, 2012
FACTS: A Complaint for a Sum of Money and Damages against petitioners was filed by respondents before RTC Cavite. In their Answer to Complaint, petitioners admitted having made purchases from respondent, but alleged that they do not remember the exact amount thereof as no copy of the documents evidencing the purchases were attached to the complaint. The respondent filed a Motion for Partial Judgment on the Pleadings contending that petitioners were deemed to have admitted in their Answer that they owed respondent the amount of P259,809.50 when they claimed that they made partial payments amounting to P130,301.80. Respondent filed a Request for Admission asking that petitioners admit the genuineness of various documents, such as statements of accounts, delivery receipts, invoices and demand letter attached thereto as well as the truth of the allegations set forth therein. The RTC ruled that the “Comments on the Request for Admission” dated 04 June 1996 is expunged from the record for being contrary to the Rules of Court. The CA dismissed the appeal. Hence, this petition.
ISSUE: Whether or not CA erred in denying petitioner’s motion for a summary judgment? NO.
HELD: NO. The CA was correct because the petition lacks merit. Summary judgment is a procedural device resorted to in order to avoid long drawn out litigations and useless delays.25 Such judgment is generally based on the facts proven summarily by affidavits, depositions, pleadings, or admissions of the parties. In the present case, it bears to note that in its original Complaint, as well as in its Amended Complaint, respondent did not allege as to how petitioners’ partial payments of P110,301.80 and P20,000.00 were applied to the latter’s obligations. In fact, there is no allegation or admission whatsoever in the said Complaint and Amended Complaint that such partial payments were made. Petitioners, on the other hand, were consistent in raising their affirmative defense of partial payment in their Answer to the Complaint and Answer to Amended Complaint. Having pleaded a valid defense, petitioners, at this point, were deemed to have raised genuine issues of fact. On the basis of the foregoing, petitioners’ defense of partial payment in their Answer to Second Amended Complaint, in effect, no longer raised genuine issues of fact that require presentation of evidence in a full-blown trial. Hence, the summary judgment of the RTC in favor of respondent is proper.