Below is a comprehensive, meticulous discussion of Specific Denials under Philippine Civil Procedure (Rule 8, particularly Sections 5, 7, 8, and 10 of the 1997 Rules of Civil Procedure as amended in 2019). This discussion integrates both the rule-based requirements and relevant jurisprudential principles. Citations to some leading Supreme Court decisions are included to illustrate how the concept of specific denials is applied.

I. OVERVIEW: THE IMPORTANCE OF SPECIFIC DENIALS

In Philippine civil procedure, pleadings are the written allegations of the parties detailing their respective claims and defenses. The complaint (or petition) sets forth the plaintiff’s cause of action, while the answer (or responsive pleading) states the defendant’s defenses.

When a defendant drafts an answer, Rule 8 of the Rules of Court governs how defenses—including denials—must be pleaded. A specific denial ensures that the defendant (a) pinpoints exactly which allegations in the complaint are denied, (b) explains the basis or reasons for the denial, and (c) whenever possible, states the substance of the matters relied upon to support the denial. Failure to comply with the rules on specific denials can lead to the inadvertent admission of material allegations in the complaint.

II. THE GOVERNING RULE: RULE 8 (ALLEGATIONS IN A PLEADING)

Under the 1997 Rules of Civil Procedure (as amended by the 2019 Amendments), Rule 8 governs how allegations must be made in pleadings and how they must be answered or denied. While the entire Rule 8 addresses various aspects of pleadings (e.g., how to plead defenses, how to allege conditions precedent, capacity, fraud, etc.), the crux of specific denials is found in Section 10 (formerly Section 10 in the 1997 Rules, retained with refinements in the 2019 Amendments).

Section 10 (Specific Denial)

A defendant must specify each material allegation of fact the truth of which the defendant does not admit, and, whenever practicable, set forth the substance of the matters upon which he or she relies to support his or her denial. Where a defendant desires to deny only a part of an averment, he or she shall specify so much of it as is true and material and shall deny only the remainder. Where a defendant is without knowledge or information sufficient to form a belief as to the truth of a material averment made in the complaint, he or she shall so state, and this shall have the effect of a denial.

From this provision, we can distill the following key points regarding specific denials.

III. FORMS OF SPECIFIC DENIALS

Philippine jurisprudence and the text of Rule 8 recognize three principal ways to effect a valid specific denial:

Absolute Denial with Explanation
- The defendant must specify each material allegation of the complaint that is being denied.
- The defendant must then set forth the substance of the matters relied upon to support the denial, whenever practicable.
Partial Denial
- If the defendant admits part of the averment and denies the other part, the answer must clearly indicate which portion is admitted and which portion is denied.
- The portion admitted is binding upon the defendant, while the disputed remainder is the subject of the denial.
Denial for Lack of Knowledge or Information
- If the defendant is truly without knowledge or information sufficient to form a belief as to the truth of an allegation, the defendant must so state in the answer.
- Such a statement is deemed a specific denial (often termed “denial by disavowal of knowledge”) as long as it is made in good faith.

Examples:

Absolute Denial: “Defendant specifically denies the allegation in paragraph 3 of the complaint that he borrowed Php 1,000,000.00 from plaintiff on January 1, 2022, on the ground that no such loan was ever granted. In support of this denial, defendant avers that on January 1, 2022, he was out of the country, as shown by his travel records attached hereto as Annex ‘1.’”
Partial Denial: “Defendant admits the allegations in paragraph 4 of the complaint only insofar as he received from plaintiff a check in the amount of Php 100,000.00; however, defendant denies the remainder of the paragraph alleging that such payment was a loan, because said check was intended by plaintiff as an investment contribution, as will be shown by the memorandum of agreement attached hereto as Annex ‘2.’”
Denial for Lack of Knowledge: “Defendant, having no personal knowledge of the alleged transaction between plaintiff and defendant’s predecessor-in-interest, and having been unable to discover evidence thereof from the documents available, denies the allegations in paragraph 2 of the complaint for lack of knowledge or information sufficient to form a belief as to their truth.”

IV. EFFECT OF A GENERAL OR INADEQUATE DENIAL

1. General Denial Deemed Admission

A mere statement that “Defendant generally denies all allegations in the complaint” or a vague “Defendant denies each and every allegation” does not constitute a valid specific denial. Such general denials or conclusory denials may be treated by the court as admissions of the material allegations in the complaint, given the requirement for specificity under Rule 8.

2. Failure to Allege Supporting Facts for the Denial

When a defendant purports to make a specific denial but fails to “set forth the substance of the matters” relied upon, the court may disregard the denial as sham or pro forma, resulting in a deemed admission of the allegation. (See, for example, Rianos v. Court of Appeals, 206 SCRA 283, discussing how a failure to adhere strictly to the specific denial rule can lead to an admission.)

3. Negative Pregnant

One particular pitfall in drafting denials is creating a negative pregnant, which is a form of denial that appears on its face to deny an allegation, but in reality admits or implies admission of the substantial facts alleged.

Illustration:
Complaint: “Defendant borrowed Php 1,000,000.00 from plaintiff on January 1, 2022, payable on March 1, 2022.”
Answer: “Defendant specifically denies borrowing Php 1,000,000.00 from plaintiff on January 1, 2022 payable on March 1, 2022 because no interest rate was agreed upon.”

This denial might be construed as a negative pregnant because it seems to deny only the aspect of the payment terms (e.g., the interest rate or the due date) but not the fact of borrowing. If not carefully worded, the defendant’s statement could be interpreted as an admission that a loan was obtained, albeit with different terms.

A negative pregnant, under Philippine jurisprudence (e.g., Dabuco v. Court of Appeals, 222 SCRA 331 [1993]), “is a denial so qualified or awkwardly phrased that it admits the substantial facts alleged.” Hence, counsel must be careful to avoid negative pregnant denials if the intent is genuinely to dispute the material allegations.

V. CONSEQUENCES OF IMPROPER DENIALS

Deemed Admissions of Material Allegations
- Under Section 11 of Rule 8, material allegations not specifically denied (except unliquidated damages) are deemed admitted. This can be fatal to a defendant’s case because admissions in pleadings bind the party.
Limitation on Issues to Be Tried
- Once an allegation is deemed admitted, it is no longer in contention; the court will no longer consider evidence to disprove the admitted fact. The scope of trial narrows, and the defendant might effectively lose on crucial elements of the plaintiff’s claim if not carefully denied.
Risk of Summary Judgment or Judgment on the Pleadings
- If the denials are inadequate and certain key facts end up admitted, the plaintiff might move for judgment on the pleadings (Rule 34) or summary judgment (Rule 35) on the ground that there are no genuine issues as to certain material facts.

VI. JURISPRUDENTIAL CLARIFICATIONS

The Supreme Court has emphasized, in multiple decisions, the need for precision and clarity in making denials:

Specific Denial Must Be Coupled With Facts Supporting the Denial
- In Heirs of David Sy v. Board of Commissioners of the HLURB (G.R. No. 179464, June 5, 2009), the Court reiterated that a denial must do more than just negate: it must point out what part of the allegation is untrue and provide an alternative version of facts, whenever practicable.
Denial for Lack of Knowledge—Requires Good Faith
- In Torres v. Specialized Packaging Development Corporation (G.R. No. 149634, August 29, 2002), the Supreme Court cautioned that “denial for lack of knowledge or information” must be done in good faith; a defendant cannot merely claim ignorance to evade a legitimate allegation without first making a reasonable inquiry.
Negative Pregnant—Actually an Admission
- In Dabuco v. Court of Appeals, 222 SCRA 331 (1993), the Court stated that a negative pregnant is “a denial which implies its affirmative opposite by seeming to deny only a trivial or immaterial part of the allegation while subtly admitting its material portion.”

VII. DRAFTING TIPS FOR SPECIFIC DENIALS

Always Identify the Paragraph or Allegation
- Use a paragraph-by-paragraph approach. For each paragraph of the complaint that is being denied, explicitly label the paragraph number in the answer.
Explain the Basis of the Denial
- If you are denying a fact, provide the actual circumstances or data that contradict the allegation (e.g., attach relevant documents, cite your own timeline of events, or point to a public record).
Avoid Vague Statements
- Phrases like “Defendant specifically denies the allegations in paragraph 5 because they are false and self-serving” without elaboration do not satisfy the rule’s requirement to “set forth the substance” of the matters relied upon.
Use Partial Denials When Applicable
- If part of the plaintiff’s statement is true and part is false, admit the true part and deny only the false portion. This builds credibility and preserves clarity on which facts remain in dispute.
Exercise Good Faith in Denials of Knowledge
- Before disclaiming knowledge or information, make a reasonable inquiry to ascertain whether you truly lack such information. Courts frown upon purely evasive “lack of knowledge” denials.
Beware of Negative Pregnant
- Carefully parse the complaint’s language. Do not inadvertently shape a denial that implicitly admits the crucial allegations.

VIII. SAMPLE STRUCTURE FOR AN ANSWER SHOWING SPECIFIC DENIALS

Below is a simplified outline illustrating how an answer might be structured to comply with Rule 8’s requirements on specific denials:

Admissions
- Identify allegations admitted. (Example: “Defendant admits paragraphs 1 and 2 of the complaint.”)
Specific Denials
- Paragraph 3: “Defendant specifically denies the allegation that … on the ground that …; hence, the alleged fact is untrue. In support of this denial, defendant points to … (Annex ‘A’).”
- Paragraph 4: “Defendant denies for lack of knowledge or information the allegation that … because after diligent inquiry with …, no record or evidence thereof was found.”
- Paragraph 5 (Partial Denial): “Defendant admits receiving money from the plaintiff, but only in the amount of Php 50,000.00. Defendant specifically denies that the amount was Php 100,000.00 and that it was a loan. Defendant avers it was partial payment for services rendered, as evidenced by … .”
Affirmative/ Special Defenses
- (If any, such as lack of jurisdiction, prescription, payment, release, waiver, statute of frauds, etc.)
Counterclaims or Cross-claims
- (If applicable.)
Prayer
- State the relief sought by the defendant.

IX. KEY TAKEAWAYS

Specific Denials under Rule 8 require that each disputed fact be singled out, explained, and supported by the factual basis of the denial whenever possible.
Improper denials—whether general, vague, or negatively pregnant—can be construed as admissions and drastically weaken a defendant’s position.
The ultimate purpose of requiring specificity is to clarify the issues for trial and avoid surprise, ensuring that only disputed allegations proceed to evidence.

By diligently applying the principles behind specific denials, parties (and their counsel) maintain clarity, avoid technical admissions, and guide the litigation efficiently to focus on the true issues in dispute.

SELECTED REFERENCES & CASES

Rules of Court (2019 Amendments), Rule 8, Sections 5–11
Dabuco v. Court of Appeals, 222 SCRA 331 (1993) – on negative pregnant.
Torres v. Specialized Packaging Development Corporation, G.R. No. 149634, August 29, 2002 – on good faith in denials for lack of knowledge.
Heirs of David Sy v. Board of Commissioners of the HLURB, G.R. No. 179464, June 5, 2009 – on specificity and the requirement to set forth supporting facts.
Rianos v. Court of Appeals, 206 SCRA 283 – on sham and pro forma denials.

CONCLUSION

A robust understanding of Specific Denials is indispensable for effective pleading practice in Philippine civil litigation. By carefully parsing each allegation, stating with precision the grounds for denial, and avoiding the pitfalls of general denials or negative pregnant denials, a defendant can properly place in issue only the facts genuinely disputed. This meticulous compliance with Rule 8 can spell the difference between a well-defended claim and an unintended admission leading to adverse judgment.