Heirs of Santos v. Heirs of Beramo
REITERATIONFacts
The Antecedents: Respondents, heirs of Crispulo Beramo and others, filed an amended complaint for reivindicacion and/or reconveyance of Lots 660, 661, and 887 of the Pilar Cadastre. They alleged that their predecessor, Don Juan Beramo, had possessed the land since 1892. The complaint further stated that the Spouses Borreros, who were entrusted with the property as a socio-industrial partner-manager-administrator, clandestinely registered the land in their name. Subsequently, the Spouses Borreros simulated an exchange with public land and later, in 1961, one-half of the subject property was sold to petitioners' predecessors, the Spouses Antonio and Luisa Esguerra Santos. These transfers were alleged to be simulated, with transferees having prior knowledge of the flawed transactions. Respondents sought to be declared rightful owners and for reconveyance of portions of the property. Procedural History: Respondents filed their Amended Complaint with the Regional Trial Court (RTC) of Roxas City, Branch 18. Petitioners, the heirs of Antonio Santos and Luisa Esguerra Santos, filed a Motion to Dismiss, arguing that the Amended Complaint stated no cause of action and that respondents failed to substantiate their claims of ownership and fraud. The RTC denied this motion, finding the grounds not indubitable. Petitioners' motion for reconsideration was also denied. Subsequently, petitioners filed a petition for certiorari with the Court of Appeals, alleging grave abuse of discretion by the RTC. The Court of Appeals dismissed the petition, holding that the RTC did not commit grave abuse of discretion and that defenses of res judicata, statute of limitations, and laches could not be raised for the first time in a certiorari petition. The Court of Appeals denied petitioners' motion for reconsideration. The Petition: Petitioners seek a review on certiorari under Rule 45 of the Rules of Court, challenging the Court of Appeals' decision affirming the denial of their motion to dismiss. They argue that the Court of Appeals erred in affirming the denial because the Amended Complaint failed to state a valid cause of action, as respondents did not present documentary proof of ownership or substantiate their fraud allegations. Furthermore, petitioners contend that the Court of Appeals erred by refusing to consider and resolve the issues of res judicata and prescription, which they had raised in their petition for certiorari.
Issue(s)
Whether the Amended Complaint states a cause of action for reivindicacion and/or reconveyance against the petitioners. Whether the Court of Appeals erred in refusing to consider the issues of res judicata and prescription raised in the petition for certiorari.
Ruling
The petition is denied for lack of merit. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of whether the Amended Complaint states a cause of action: The Court held that the contention of the petitioners lacks merit. The determination of whether a complaint states a cause of action, when the ground for dismissal is Section 1(g), Rule 16 of the Rules of Court, must be based on the allegations within the complaint itself. In a motion to dismiss, the defendant is deemed to hypothetically admit the truth of the material allegations presented by the plaintiff. For a motion to dismiss to be sustained on this ground, the complaint must clearly demonstrate that the claimed relief does not exist. The Court agreed with the Court of Appeals that the Amended Complaint sufficiently stated a cause of action for reivindicacion and/or reconveyance. The allegations that respondents' predecessor, Don Juan Beramo, had open, continuous, exclusive, and notorious possession since 1892, that the property was entrusted to Cornelio Borreros, and that subsequent titling and transfers were simulated and fraudulent, sufficiently averred that respondents are the rightful owners and the property was wrongfully registered by petitioners' predecessors. The Court reiterated that respondents were not required to present or append proof of their allegations in the complaint to establish a sufficient cause of action at this preliminary stage; such proof is to be presented during the trial on the merits. The complaint does not need to establish or allege facts proving the existence of a cause of action at the outset, as this is a matter for trial. On the issue of whether the Court of Appeals erred in refusing to consider the issues of res judicata and prescription: The Court found this contention unmeritorious. The Court of Appeals correctly held that defenses such as res judicata, statute of limitations, and laches cannot be raised for the first time in a special civil action for certiorari under Rule 65 of the Rules of Court. This principle is well-established, as an issue not raised in the trial court cannot be raised for the first time on appeal. The Court cited the ruling in Buñag v. Court of Appeals, which explicitly states that this principle applies to special civil actions for certiorari. Therefore, the Court of Appeals did not err in refusing to consider these defenses, as they were not properly raised before the trial court and were being introduced for the first time in the certiorari petition.
Main Doctrine
A motion to dismiss based on the ground that the complaint states no cause of action must be determined from the allegations in the complaint itself, and the defendant hypothetically admits the truth of these allegations for the purpose of resolving the motion. The complaint need not establish or allege facts proving the existence of a cause of action at the outset; this is to be done during the trial on the merits.