Suyom v. Collantes
REITERATIONFacts
The Antecedents: Petitioners filed a complaint for annulment of sales with damages against respondents. They alleged that Catalina Perez Suyom and the late Juan Suyom were conjugal owners of a parcel of land. Juan Suyom appointed Pedro Miniano as tenant in 1944. After Juan Suyom's death in 1949, Catalina retained Miniano as tenant, entrusting the land and its title to him when she left for Samar in 1950. Upon her return in 1965, she demanded her share of the coconut harvests from Miniano, who repeatedly gave excuses. In 1973, petitioners discovered the property was in the possession of Antonio Sacay. Sacay claimed ownership, stating he bought it from Uldarico Orgong, who allegedly bought it from Miniano. Miniano, in turn, allegedly purchased the land from the deceased Juan Suyom. Petitioners alleged that the signature of Juan Suyom on the Deed of Sale to Miniano was a forgery. They further claimed that Miniano, in collusion with other defendants, executed the deed with malicious intent to defraud. Antonio Sacay, through fraudulent representation and collusion, obtained the title entrusted to Gerardo Suyom (Juan Suyom's nephew, not an heir) by taking advantage of his ignorance and illiteracy, and made him sign a Deed of Confirmation of Sale. This enabled the registration of the deeds of sale, resulting in a Transfer Certificate of Title issued to Sacay. Petitioners argued that even if Juan Suyom executed the sale, it was not binding on Catalina as her consent as co-owner was not obtained. They also asserted that Miniano, as a mere tenant, had no capacity to dispose of the property, rendering all subsequent transactions void ab initio due to fraud and deceit. They demanded the return of the property and claimed damages and attorney's fees. Procedural History: Private respondents filed a motion to dismiss, alleging (1) no cause of action, (2) claim barred by laches, and (3) cause of action barred by the Statute of Limitations. Petitioners opposed, arguing their complaint stated causes of action based on fraud and deceit, that their claims were not barred by laches as they did not sleep on their rights, and that the causes of action were not barred by prescription as they were predicated on fraud. The trial court, on December 12, 1974, issued an order dismissing the complaint. Petitioners' motion for reconsideration was denied on February 24, 1975. The Petition: Petitioners seek review on certiorari of the dismissal orders, arguing the trial judge was not justified in sustaining the motion to dismiss.
Issue(s)
Whether the trial court was justified in dismissing the complaint for lack of cause of action. Whether the causes of action were barred by laches and the Statute of Limitations.
Ruling
The Supreme Court nullified and set aside the questioned Orders dated December 12, 1974, and February 24, 1975, of the Court of First Instance of Leyte, and ordered the case remanded to the court a quo for further proceedings. Costs were against private respondents.
Ratio Decidendi
On Issue 1: The Court ruled that the trial court acted hastily because the grounds for dismissal were not indubitable under Section 3, Rule 16 of the Rules of Court. In a motion to dismiss for lack of cause of action, the court must hypothetically admit the truth of the allegations; thus, the court must assume that the signature of Juan Suyom was indeed a forgery and that the transfers were products of collusion. Since a forged deed conveys no title and a tenant cannot validly dispose of the landlord's property, these allegations, if true, provide a sufficient legal basis for the court to render a valid judgment in favor of the petitioners. If the veracity of these allegations is challenged, the court must require an answer and proceed to trial rather than dismissing the case summarily. The Court cited Galeon v. Galeon to emphasize that the sufficiency of the allegations to constitute a cause of action is the only matter for determination, not their actual truth. On Issue 2: The Court held that a motion to dismiss on the ground of prescription should not be granted if the face of the complaint does not show that the action has already prescribed. In this case, the complaint did not state a specific date from which the prescriptive period could be calculated, nor did the respondents' motion provide a definitive starting point. Following the rulings in Francisco v. Robles and Sison v. McQuaid, the absence of such data means there is no way for the court to determine if the period has run without receiving evidence. Furthermore, the allegation of collusion among the respondents implies a conspiracy to defraud the petitioners, which the respondents are deemed to have admitted for the purpose of the motion to dismiss. Such issues of fraud and collusion require the presentation of evidence during a trial on the merits to be properly adjudicated.
Main Doctrine
A motion to dismiss based on lack of cause of action, prescription, or laches should not be granted if the complaint, on its face, sufficiently alleges facts that, if proven, would entitle the plaintiff to the relief prayed for, especially when fraud and collusion are alleged, necessitating a trial on the merits.