G.R. No. L-33123 November 22, 1977
DR. DEOGRACIAS CAMON, petitioner, vs. HON. CARLOS ABIERA, Presiding Judge of the Court of First Instance of Negros Occidental, THE PROVINCE OF NEGROS OCCIDENTAL, RUFINO SUPLIDO, RAYMUNDO SANCHO, CIPRIANO PET, in his capacity as 3rd District Engineer, HONESTO GALENO, Officer in charge of Equipment, 3rd Engineering District, and DANIEL MEDES, respondents.

FACTS

Petitioner Dr. Deogracias Camon filed a complaint for damages, alleging the provincial board of Negros Occidental allowed him to rent a government bulldozer for six days for use on his leased sugarland. He paid the rental in advance to District Engineer Cipriano Pet. However, Pet and equipment officer Honesto Galeno refused delivery. Instead, the bulldozer, operated by driver Daniel Medes, was used for nine months on the adjoining land of respondent Raymundo Sancho, whose cultivation was financed by respondent Rufino Suplido. Camon further alleged that Suplido and Sancho obstructed his land with stones and that later, Medes forcibly entered another portion of his prepared land with the bulldozer, scraping the topsoil and devastating the area, with the soil transferred to Sancho’s hacienda.
During pre-trial, the respondent judge made premature remarks adopting the theory of defendants Sancho and Suplido, suggesting Camon was motivated by “hatred and jealousy.” The judge then directed defendants to file any desired pleadings. Defendants Suplido, Sancho, and Medes filed motions to dismiss for lack of cause of action, which Camon opposed. After an inexcusable delay of over fifteen months, Judge Abiera issued a poorly worded order granting the motions and dismissing the case. Camon appealed, arguing denial of due process.

ISSUE

Whether the trial court erred in dismissing the complaint on a motion to dismiss for lack of cause of action.

RULING

Yes. The Supreme Court reversed the order of dismissal. The legal logic is grounded in the fundamental right to due process. A motion to dismiss based on lack of cause of action hypothetically admits the truth of the material allegations of the complaint. Camon’s complaint, on its face, sufficiently alleged a cause of action for damages arising from the alleged wrongful withholding of the leased bulldozer, its unauthorized use for the benefit of other parties, and the subsequent acts of devastation to his property. These factual allegations, which were specifically denied by the defendants in their answers, clearly raised genuine issues of fact regarding the existence of a lease contract, breach thereof, and the resulting damages. Such issues of fact cannot be resolved in a mere motion to dismiss; they require a full trial on the merits where evidence can be presented and evaluated. The Court cited established doctrine that dismissal upon a motion to dismiss constitutes a denial of due process when the pleadings reveal contested factual issues necessitating a trial. The trial court’s duty was to proceed to trial, not to preemptively terminate the case. The order was set aside and the lower court was directed to try the case.