GR 176598; (July, 2014) (Digest)
G.R. No. 176598 ; July 9, 2014
Petronio Clidoro, et al., Petitioners, vs. Augusto Jalmanzar, et al., Respondents.
FACTS
This case originated from a complaint for revival of judgment filed by respondents (Rizalina Clidoro, et al.) to revive a 1995 Court of Appeals Decision ordering the partition of the estate of the late Mateo Clidoro. The petitioners (defendants below) moved to dismiss the complaint, arguing it stated no cause of action as it was not brought by or against the real parties-in-interest, noting many original litigants were already deceased and substitution was allegedly improper.
The Regional Trial Court granted the motion to dismiss, agreeing the complaint was flawed because deceased persons were named as parties, contrary to the rules on real parties-in-interest. The RTC held the suit was not brought by the proper parties. Respondents moved for reconsideration and sought to admit an Amended Complaint to implead additional heirs, but this was denied.
ISSUE
Whether the complaint for revival of judgment was correctly dismissed by the RTC for lack of cause of action due to alleged improper parties and lack of real parties-in-interest.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ reversal of the RTC’s dismissal. The Court clarified that a motion to dismiss based on “lack of cause of action” is procedurally incorrect; the proper ground is “failure to state a cause of action” under Rule 16, which tests the legal sufficiency of the allegations hypothetically admitted as true. The complaint sufficiently stated a cause of action by alleging the final judgment and the parties’ interest in its enforcement.
On the substantive issue, the Court ruled that not all co-owners or heirs need to be joined as plaintiffs in an action for revival of judgment. Citing Basbas v. Sayson, the Court held that even one co-owner, acting alone, can bring such an action to recover co-owned property, as the judgment would benefit all. Thus, respondents, as heirs of prevailing parties in the partition case, were real parties-in-interest entitled to seek revival. The question of their specific interests was a matter for trial, not a ground for dismissal. The RTC erred in dismissing the complaint; the case was remanded for further proceedings.