ANACLETO R.

MENESES
v.
SECRETARY OF AGRARIAN REFORMS

FACTS:

Anacleto Meneses, et al. co-owned of a parcel of rice land, which was

distributed to farmerbeneficiaries through the government’s land reform
program. Petitioners then lodged a claim for payment of just compensation
rentals had not been paid since the distribution to the farmer beneficiaries..
Respondent Department of Agrarian Reform contends that the filing of the
case is premature because valuation has to be determined before any resort
to the court. Farmer-beneficiaries claimed that they had no unpaid rents and
the jurisdiction over the case belongs to the Department of Agrarian
Reform Adjudication Board (DARAB). The parties during the hearing
agreed that the sole issue to be resolved is whether or not Petitioners were
entitled to just compensation. Thus, the trial court issued an order giving
the parties a period within which to file their respective motions for
judgment on the pleadings or comments, after which the case shall be
deemed submitted for resolution. The trial court dismissed the complaint
while Court of Appeals affirmed the said decision.

ISSUE:

Whether or not the motion for judgment on pleadings was appropriate.

HELD:

Judgment on the pleadings is proper when an answer fails to render an

issue or otherwise admits the material allegations of the adverse party's
pleading according to Section 1 Rule 34 of the Rules of Court. The
essential question is whether there are issues generated by the pleadings.
A judgment on the pleadings may be sought only by a claimant, who is
the party seeking to recover upon a claim, counterclaim or cross-claim; or
to obtain a declaratory relief. Respondents filed separate answers which
by themselves tendered issues, as it made specific denials of the material
allegations in the complaint and asserted affirmative defenses, which
would bar recovery by petitioners. Furthermore, it was erroneous for the
trial court to require a motion for judgment on the pleadings filed by the
Secretary of Agrarian Reform since it has no legal standing. It was clearly
meant by the trial court that a motion for summary judgment was the more
proper recourse, which is designed for the prompt disposition of actions
and may be rendered if the pleadings on file show that, after a summary
hearing, there is no genuine issue regarding any material fact. The moving
party is thus entitled to a judgment as a matter of law.