Lim v. De Los Santos
REITERATIONFacts
The Antecedents: Defendants contracted to sell subdivision lots to plaintiffs, with payments to be considered liquidated damages and rentals upon failure to pay installments, or purchase price upon full payment. The contracts did not explicitly mention the construction of roads but included a stipulation allowing vendor representatives to enter the property for inspection and utility installations. Plaintiffs alleged that defendants failed to construct necessary roads for ingress and egress, despite promises made prior to and during the execution of the contracts, which were essential for the lots to be habitable and valuable. Plaintiffs had complied with their obligations, begun or contracted for house construction, and relied on these representations. Procedural History: Defendants filed a motion to dismiss, alleging the complaint stated no cause of action and plaintiffs lacked legal capacity to sue. The trial court granted the motion. Plaintiffs moved for reconsideration, insisting on the alleged promise to construct roads. The court, after a hearing limited to evidence on this allegation, denied the motion, finding the promise to be verbal and not in the written agreements. The Petition: Plaintiffs appealed the dismissal order, arguing that the complaint sufficiently stated a cause of action based on the alleged oral representations and that they had the legal capacity to sue.
Issue(s)
Whether the complaint states a cause of action to compel the defendants to construct roads. Whether the plaintiffs have the legal capacity to sue to enforce Quezon City Ordinance No. 2969 and subdivision regulations.
Ruling
The Supreme Court set aside the order of dismissal and remanded the case for further proceedings. The Court held that the complaint stated a cause of action and that the plaintiffs had the legal capacity to sue.
Ratio Decidendi
On the first issue (cause of action): The Court opined that the complaint did state a cause of action. The lower court erred in dismissing the complaint solely based on the absence of an express obligation in the written contract, ignoring the specific allegations of fact in paragraph VI of the complaint. These allegations averred that prior to and simultaneously with the execution of the contracts, the defendant represented that she would construct adequate outlets to a public highway, and that plaintiffs relied on these representations, making disbursements and altering their position to their detriment, particularly by constructing their residences. The Court clarified that the rule on the parol evidence is a rule of evidence concerning the merits of the case, not a ground for dismissing a complaint for failure to state a cause of action. The Court also noted that subdivision regulations at the time required paved roadways, implying a seller's duty to provide access. The Court found the allegations of oral promises not improbable, as proper access is essential to the enjoyment of a property. On the second issue (legal capacity to sue): The Court found the trial court's reliance on Subido vs. City of Manila to be misplaced. In that case, a private citizen could not contest an ordinance without proof of special injury. Here, the plaintiffs sought to compel another private party to comply with regulations requiring road construction within the subdivision, which directly afforded access to their lots. The absence of such roads caused them a special injury distinct from any damage to the community. Furthermore, the Court reiterated that the alleged representation by the defendant to construct roads constituted a distinct cause of action, irrespective of the regulations and ordinances invoked.
Main Doctrine
A complaint states a cause of action if it alleges facts, which, if true, would entitle the plaintiff to relief, even if such facts are based on oral representations made prior to or simultaneous with a written contract, especially when the plaintiff has acted to their detriment in reliance on such representations. The rule on the parol evidence is a rule of evidence, not a ground for dismissal of a complaint for failure to state a cause of action.