Malicdem v. Flores
REITERATIONFacts
The Antecedents: This case concerns a lease agreement entered into on August 3, 1993, between Dr. Apolinario G. Bautista, then dean of Pangasinan State University (PSU), and respondent Romeo Flores, along with Francisco Lotivio. The agreement allowed Flores and Lotivio to lease the PSU canteen building and general merchandise store for a monthly rent of P1,200, with the understanding that they would initially shoulder the costs of repair and renovation. This rent was to be deducted from their renovation expenses until fully reimbursed. The lease was for a term of six years, from September 16, 1993, to September 15, 1999, with a provision for extension by mutual agreement. Lotivio later withdrew from the partnership in 1995. Respondent Flores alleged that PSU assured him of a contract renewal to recoup his expenses. Procedural History: Before the contract's expiration, respondent Flores was informed by the new dean, petitioner Dr. Melanio Malicdem, that the lease would not be renewed and that the term was extended only until October 31, 1999. Despite Flores's repeated requests for renewal, PSU's decision was finalized on November 17, 1999. Consequently, Flores filed a case for specific performance and damages, seeking a temporary restraining order (TRO) and preliminary injunction against PSU and its officials, including petitioners Malicdem and Roy C. Ferrer. The trial court initially scheduled a hearing for the TRO, which was reset. PSU, through Dr. Rodolfo Asanion, filed an answer, asserting the contract was unauthorized and that PSU had previously advised Flores of its termination. PSU also argued that the contract violated auditing regulations regarding public bidding and term limits. Petitioners later filed a motion to dismiss, which the trial court denied, finding that the motion was filed after the answer and that the issues required a full hearing. Petitioners' motion for reconsideration was also denied. They then filed a special civil action for certiorari with the Court of Appeals, arguing the trial court gravely abused its discretion in denying the motion to dismiss. The Court of Appeals dismissed this petition and denied their motion for reconsideration. The Petition: Petitioners Dr. Melanio Malicdem and Roy C. Ferrer filed this petition for review on certiorari under Rule 45 of the Rules of Court, assailing the Court of Appeals' decision. They contend that the Court of Appeals erred in affirming the trial court's order denying their motion to dismiss. Specifically, they argue that the trial court lacked sufficient basis for its order and that respondent Flores failed to state a cause of action against them. The Supreme Court, however, found the petition without merit. It ruled that a special civil action for certiorari was not the proper remedy to question the denial of a motion to dismiss, as such an order is interlocutory. Furthermore, the Court found that the trial court did not commit grave abuse of discretion, noting that the motion to dismiss was procedurally flawed for being filed after the answer. The Court also held that the trial court's order sufficiently stated its reasons for denial and that the complaint, at the very least, stated a cause of action for damages, with the veracity of the allegations to be determined during a full trial on the merits.
Issue(s)
Whether the Court of Appeals erred in ruling that the trial court stated sufficient basis in denying petitioners’ motion to dismiss. Whether the Court of Appeals erred in affirming the trial court’s order denying petitioners’ motion to dismiss; and whether the motion to dismiss was procedurally flawed. Whether the Court of Appeals erred in ruling that respondent sufficiently stated a cause of action against petitioners; and on proceeding to trial.
Ruling
The petition is denied. The assailed decision and resolution of the Court of Appeals are affirmed. Costs against petitioners.
Ratio Decidendi
On the propriety of certiorari: The special civil action for certiorari filed by petitioners with the Court of Appeals was not the proper remedy to assail the denial of the motion to dismiss. The order denying the motion to dismiss is merely interlocutory, as it does not finally dispose of the case. The general rule is that such denial cannot be questioned via certiorari under Rule 65, which is designed to correct errors of jurisdiction, not errors of judgment. While exceptions exist where grave abuse of discretion is shown, petitioners failed to demonstrate such abuse by the trial court in this case. Therefore, the Court of Appeals did not err in upholding the trial court's order. On the procedural defect of the motion to dismiss and the trial court's stated basis for denial: The motion to dismiss was procedurally flawed because it was filed after petitioners had already submitted an answer to the complaint. Section 1, Rule 16 of the Rules of Court explicitly states that a motion to dismiss must be filed "within the time for but before filing the answer to the complaint or pleading asserting a claim." The records clearly show that petitioners, through Dr. Asanion, filed an answer on December 20, 1999, and subsequently filed the motion to dismiss on January 21, 2000. This procedural misstep alone was sufficient ground to deny the motion. The answer filed by Dr. Asanion as PSU official bound the petitioners, as they were sued in their official capacities. Petitioners' contention that the trial court failed to state its reasons for denial is incorrect. The trial court's order adequately complied with Section 3, Rule 16 by narrating the conflicting claims of the parties and concluding that their divergent positions warranted a full-blown hearing. Furthermore, the denial based on the motion being filed after the answer was a sufficient ground. The requirement for specificity of rulings under Article VIII, Section 14 of the Constitution and Rule 36 primarily applies to judgments and final orders, with a more liberal interpretation allowed for interlocutory orders. On the sufficiency of the cause of action and on proceeding to trial: Contrary to petitioners' assertion, the allegations in the complaint sufficiently stated a cause of action, at the very least, for damages. Section 1, Rule 8 of the Rules of Court requires only the allegation of ultimate facts. A cause of action has three elements: a right in favor of the plaintiff, an obligation on the part of the defendant to respect that right, and an act or omission by the defendant violating the plaintiff's right or breaching the obligation. Even if PSU was not legally compelled to renew the contract or if there were procedural defects in the original lease, the focus in a motion to dismiss for failure to state a cause of action is on the sufficiency of the allegations, not their veracity. The complaint, when hypothetically admitting the truth of its allegations, could allow the court to render a valid judgment. The veracity of the claims, including whether prior approval for repairs was secured, is a matter for trial on the merits. The Supreme Court reiterated the principle that in cases where a motion to dismiss is denied, the movant is not deprived of the right to present their case and submit evidence to rebut the allegations. The trial court should be given the opportunity to evaluate the evidence, apply the law, and decree the proper remedy. Therefore, the parties should proceed with the trial to determine their respective rights and obligations, as issues requiring factual determination, such as the existence of a cause of action for damages or defenses like estoppel or laches, are best resolved after trial on the merits.
Main Doctrine
The denial of a motion to dismiss, being an interlocutory order, cannot generally be questioned via a special civil action for certiorari under Rule 65 of the Rules of Court, unless grave abuse of discretion is clearly demonstrated. Furthermore, a motion to dismiss must be filed before the answer to the complaint, and a complaint need only allege ultimate facts constituting a cause of action, with its veracity to be determined during trial on the merits.