Philippine Army v. Pamittan
REITERATIONFacts
The Antecedents: Respondents, who had been occupying and residing on land for twenty to thirty years, filed a complaint for Damages, Injunction with Prayer for a Writ of Preliminary Mandatory Injunction, and Temporary Restraining Order against petitioners, high-ranking officials of the Philippine Army. Respondents averred that their houses were demolished on July 3, 2006, upon orders of petitioners, despite their claim that the land was part of the Department of Agriculture (DA) Breeding Station and not within a military reservation. They asserted that the demolition was illegal as it was done without a court order. Procedural History: The Regional Trial Court (RTC) issued a temporary restraining order (TRO) on July 12, 2006. The Office of the Solicitor General (OSG) moved to dismiss the complaint, arguing lack of cause of action, jurisdiction, and entitlement to injunctive relief. The RTC granted the motion to dismiss on April 11, 2007, and denied the motion for reconsideration on June 19, 2007. The Court of Appeals (CA) reversed the RTC's orders, setting aside the dismissal and remanding the case for further proceedings, also issuing a writ of preliminary injunction. The Petition: Petitioners filed a petition for review assailing the CA's decision and resolution, arguing that the CA erred in setting aside the RTC's orders and remanding the case for a full-blown trial.
Issue(s)
Whether the Court of Appeals erred in setting aside the orders of the RTC and remanding the case to the RTC for a full-blown trial. Whether the respondents have a valid cause of action against the petitioners for damages and injunction.
Ruling
The Supreme Court granted the petition, set aside the decision and resolution of the Court of Appeals, and reinstated the orders of the Regional Trial Court dismissing the complaint.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in setting aside the orders of the RTC and remanding the case to the RTC for a full-blown trial: The Supreme Court found the petition meritorious. It reiterated that while a motion to dismiss based on failure to state a cause of action hypothetically admits the truth of the allegations, this rule has exceptions. The court may consider other pleadings and documents appended to the complaint, especially when the allegations are demonstrably unfounded by record or document. In this case, the RTC correctly considered the survey report of the Department of Environment and Natural Resources (DENR) and the Construction Permit signed by the respondents. These documents contradicted the respondents' claim that the land was part of the DA Breeding Station and not within the military reservation. The DENR survey clearly indicated that the area occupied by the respondents was within the military reservation. Furthermore, the Construction Permit signed by the respondents in 1994 explicitly stated conditions, including the obligation to vacate the premises upon retirement or when the area is needed for military use, subject to 30 days' notice. These pieces of evidence, considered by the RTC, sufficiently defeated the respondents' claim and demonstrated the insufficiency of their cause of action. On the issue of whether the respondents have a valid cause of action against the petitioners for damages and injunction: The Supreme Court held that the respondents did not have a valid cause of action. The RTC found, based on the DENR survey, that the land occupied by the respondents was within the military reservation. This finding was supported by the evidence presented. Moreover, the respondents had signed a Construction Permit in 1994, which granted them permission to construct houses on a portion of the military reservation subject to specific conditions. One of these conditions was that the area could be returned to the control of the Camp Commander if needed for military use, with 30 days' notice. The demolition was effected after demands to vacate were made and ignored, and in accordance with the terms of the Construction Permit. The Court cited Custodio v. Court of Appeals, stating that there is no cause of action for lawful acts done by the owner on his property, even if such acts cause incidental damage. The RTC also correctly found that the petitioners could not be held personally accountable as the demolition was done in connection with their official duties under "Oplan Linis," without evidence of ultra vires acts or bad faith. Therefore, the RTC's dismissal of the complaint for lack of cause of action was proper.
Main Doctrine
A motion to dismiss based on failure to state a cause of action hypothetically admits the truth of the allegations in the complaint, but this rule is not without exception. The court may consider other pleadings and documents appended thereto, especially when the allegations in the complaint are contradicted by documentary evidence on record.