G.R. No. 198680 ; July 8, 2013
HEIRS OF MAGDALENO YPON, NAMELY, ALVARO YPON, ERUDITA Y. BARON, CICERO YPON, WILSON YPON, VICTOR YPON, AND HINIDINO Y. PEÑALOSA, PETITIONERS, vs. GAUDIOSO PONTERAS RICAFORTE A.K.A. “GAUDIOSO E. YPON,” AND THE REGISTER OF DEEDS OF TOLEDO CITY, RESPONDENTS.

FACTS

Petitioners, alleging to be the collateral relatives and successors-in-interest of the intestate and childless decedent Magdaleno Ypon, filed a complaint for Cancellation of Title and Reconveyance with Damages against respondent Gaudioso Ponteras Ricaforte. They claimed that Gaudioso, representing himself as Magdaleno’s sole heir, executed an Affidavit of Self-Adjudication over several lots, causing the cancellation of the original titles and their transfer to his name, to their prejudice.
In his Answer, Gaudioso asserted he is Magdaleno’s lawful son, presenting his Certificate of Live Birth and other documents as evidence. By way of affirmative defense, he claimed petitioners had no cause of action and were not the real parties-in-interest since they had not been judicially declared as Magdaleno’s lawful heirs.

ISSUE

Whether the Regional Trial Court properly dismissed the complaint for cancellation of title and reconveyance on the ground of failure to state a cause of action.

RULING

Yes, the dismissal was proper. A cause of action exists if, based solely on the complaint’s allegations admitted as true, the plaintiff is entitled to the relief sought. Here, petitioners’ complaint alleged they are Magdaleno’s lawful heirs and sought the nullification of Gaudioso’s Affidavit of Self-Adjudication and the consequent cancellation of titles.
However, the Supreme Court ruled that the determination of who are the lawful heirs of a decedent is a matter that must be resolved in a proper special proceeding for the settlement of estate, not in an ordinary civil action such as this suit for cancellation of title and reconveyance. Jurisprudence consistently holds that a declaration of heirship can only be made in a special proceeding, as it seeks to establish a status or right. An ordinary civil action is for the enforcement or protection of a right, not for establishing heirship.
Since the reliefs petitioners prayed for were fundamentally premised on a judicial declaration of their status as lawful heirs—a declaration the trial court could not make in this ordinary action—the complaint indeed failed to state a cause of action upon which relief could be granted. The RTC correctly dismissed the case. The proper recourse for petitioners is to institute a special proceeding for the settlement of Magdaleno’s estate where the issue of heirship can be conclusively determined.