University of the Philippines v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents Manuel Elizalde and Tasaday representatives Balayem, Mahayag, Dul, and Lobo filed a complaint for damages and declaratory relief against UP professors Zeus Salazar and Jerome Bailen. The complaint alleged that Salazar and Bailen made defamatory statements and conducted efforts to deny the existence and distinct ethnic community of the Tasadays, claiming the 'discovery' was a fabrication. These allegations stemmed from presentations at an international conference and subsequent publicity regarding the Tasaday controversy. Procedural History: UP filed a motion to intervene, asserting its right to protect its faculty under academic freedom and its own institutional academic freedom. The RTC granted UP's motion to intervene and admitted its answer in intervention. Salazar and Bailen filed a motion to dismiss, which was denied by the RTC. Their subsequent petition for certiorari was dismissed by the Supreme Court. UP then filed its own motion to dismiss, which was stricken off the record by the RTC. UP's motion for reconsideration was denied, with the RTC holding that UP could no longer file a motion to dismiss after filing an answer in intervention. UP then filed a motion for a preliminary hearing on its special defenses (lack of cause of action and jurisdiction), which the RTC denied. The RTC reasoned that the grounds raised by UP were already passed upon in the denial of the original defendants' motion to dismiss, which was sustained by the Supreme Court. UP's petition for certiorari and prohibition before the Court of Appeals was dismissed. The Court of Appeals held that the motion to dismiss could not be granted on grounds not stated in the complaint and that the RTC had jurisdiction over the complaint for damages. The Petition: UP filed the instant petition for review on certiorari, assailing the Court of Appeals' decision affirming the RTC's denial of UP's motion to dismiss.
Issue(s)
Whether the University of the Philippines (UP) can file a motion to dismiss the complaint after filing an answer in intervention. Whether the allegations in the complaint regarding the acts and statements of Professors Salazar and Bailen are protected by institutional academic freedom and are privileged communications, thus failing to state a cause of action. Whether the lower court correctly denied UP's motion to dismiss based on lack of cause of action and lack of jurisdiction. Whether the principle of res judicata applies to the instant petition. Whether the prayer for a declaration of the Tasadays as a distinct ethnic community is appropriate in this case. Whether the primary object of the complaint is to hold the defendants liable for damages arising from alleged wrongful acts.
Ruling
The Supreme Court affirmed the Order of the lower court and the Decision of the Court of Appeals. The lower court is directed to proceed with the hearing of the case with dispatch.
Ratio Decidendi
On the propriety of UP's motion to dismiss after intervention: The Court held that UP, having filed an answer in intervention, could no longer file a separate motion to dismiss. Its attempt to do so was correctly stricken off the record. While UP's subsequent motion for a preliminary hearing on its special defenses was treated as if a motion to dismiss had been filed, the grounds raised were not evident from the face of the complaint. The Court reiterated that an intervenor's role is to join parties, not to initiate a dismissal after joining. On the alleged lack of cause of action due to academic freedom: The Court found that the motion to dismiss, whether direct or through affirmative defenses treated as such, must be resolved based solely on the allegations in the complaint. The complaint did not allege that UP authorized the acts of Salazar and Bailen, nor did it state that their trip was sanctioned by UP. Therefore, UP's claim of institutional academic freedom as a ground for dismissal was not evident from the complaint itself. The Court noted that UP should have championed this defense during the trial rather than attempting to abort the proceedings at the outset. On the denial of UP's motion to dismiss and special defenses: The Court affirmed the lower court's denial, emphasizing that the grounds for dismissal must be apparent from the complaint. UP's defenses, particularly regarding academic freedom, were matters to be proven during trial. The Court also pointed out that the issues raised by UP regarding academic freedom were substantially the same as those raised by the original defendants, whose motion to dismiss was already denied and upheld by the Supreme Court in a prior petition. On the applicability of res judicata: The Court ruled that res judicata did not apply because, while there was substantial identity of parties and interests, there was a want of identity of the subject matter. The prior petition in G.R. No. 87248 concerned the denial of the original defendants' motion to dismiss. The instant petition, however, stemmed from the denial of UP's attempt to dismiss the complaint after it had intervened and filed an answer, and subsequently from the denial of its motion for a preliminary hearing on its special defenses. The Court stressed that res judicata should not be applied rigidly when justice might be sacrificed. On the prayer for declaratory relief: The Court cautioned the lower court that the prayer for a declaration of the Tasadays as a distinct ethnic community might be akin to a prayer for judicial declaration of citizenship, which is generally not granted in a petition for declaratory relief. On the primary object of the complaint: The Court acknowledged that the primary object of the complaint was to hold the defendants liable for damages arising from alleged wrongful acts, and the prayer for declaratory relief was a minor aspect.
Main Doctrine
A motion to dismiss based on lack of cause of action must be resolved solely on the basis of the allegations in the complaint, without considering extraneous matters or defenses not pleaded therein. An intervenor cannot file a motion to dismiss after filing an answer in intervention, and its attempt to do so by raising special defenses is treated as if a motion to dismiss had been filed, but the grounds must be evident from the complaint itself.