Sumalinog v. Doronio
REITERATIONFacts
The Antecedents: Petitioner Godofreda B. Sumalinog was hired by respondent Corazon Doronio to wash clothes. After washing the clothes, petitioner returned them, and Corazon received them without complaint. Subsequently, Corazon's son, Israel Doronio, informed petitioner that she was being accused by Corazon of stealing the clothes, which petitioner denied. Upon returning to their barrio, petitioner again denied the charge to Corazon. Despite knowing petitioner's innocence, Corazon and Israel Doronio, allegedly impelled by legal malice, filed a criminal complaint for qualified theft against petitioner. Petitioner alleged that Corazon's affidavit did not establish the elements of qualified theft, specifically "domestic servant" and "grave abuse of confidence." Respondent Lorenzo Rivera, the Chief of Police, allegedly filed the complaint without probable cause. Petitioner was subsequently acquitted of the charge of qualified theft by the Municipal Court of Borbon, Cebu. Procedural History: Petitioner filed a complaint for damages based on malicious prosecution against Corazon Doronio, Israel Doronio, and Lorenzo Rivera. The private respondents moved to dismiss the complaint for failure to state a cause of action. The Court of First Instance of Cebu dismissed the complaint, rationalizing that Corazon Doronio acted with probable cause and not with improper or sinister motive or legal malice, and that an accused can be convicted on circumstantial evidence or uncorroborated testimony if guilt is proven beyond reasonable doubt. The Petition: Petitioner appealed the dismissal to the Court of Appeals, which certified the case to the Supreme Court as the issue involved was one of law.
Issue(s)
Whether the court below erred in dismissing the complaint on the ground that it states no cause of action. Whether the allegations in the complaint sufficiently establish a cause of action for malicious prosecution.
Ruling
The Supreme Court ruled that the court below erred in dismissing the complaint. The order of dismissal was set aside, and the case was remanded to the court a quo for further proceedings.
Ratio Decidendi
On the issue of whether the court below erred in dismissing the complaint on the ground that it states no cause of action: The Supreme Court held that the court below committed an error in dismissing the complaint. The cardinal principle is that facts pleaded in the complaint are deemed accepted by the defendants who file a motion to dismiss for failure to state a cause of action. The test of sufficiency of alleged facts is whether the court could render a valid judgment as prayed for, accepting as true the exclusive facts set forth in the complaint. If the court doubts the truth of the averments, it must not dismiss the complaint but require an answer and proceed to trial on the merits. The Court cited Boncato vs. Siason and Republic Bank vs. Cuaderno in support of this principle. On the issue of whether the allegations in the complaint sufficiently establish a cause of action for malicious prosecution: In the instant case, a perusal of the complaint showed sufficient allegations to sustain an action for damages based on malicious prosecution. The averments that the petitioner was prosecuted for and acquitted of qualified theft, that the action was brought by private respondents without probable cause, and that they were impelled by malice, sufficiently point out the right of action of the petitioner against the private respondents. Therefore, the dismissal was premature and erroneous.
Main Doctrine
A complaint for damages based on malicious prosecution sufficiently states a cause of action if it alleges that the petitioner was prosecuted for a crime, subsequently acquitted, that the action was brought by the respondents without probable cause, and that the respondents were impelled by malice.