GR 109173; (July, 1996) (Digest)
G.R. No. 109173 July 5, 1996
CITY OF CEBU, petitioner, vs. THE HON. COURT OF APPEALS (SIXTEENTH DIVISION), HON. JUDGE RODOLFO BELLAFLOR and MERLITA CARDENO, respondents.
FACTS
The City of Cebu filed a complaint for eminent domain against Merlita Cardeno to expropriate her 2,019-square-meter land for a socialized housing project. The complaint alleged that “repeated negotiations had been made with the defendant to have the aforementioned property purchased by the plaintiff through negotiated sale without resorting to expropriation, but said negotiations failed.” Cardeno moved to dismiss, arguing the complaint lacked a cause of action for failing to allege compliance with Section 19 of the Local Government Code (R.A. 7160), which requires that “a valid and definite offer has been previously made to the owner, and such offer was not accepted.” The City, in its opposition, specified a definite offer of P478,000 made on October 28, 1991, which was refused.
The Regional Trial Court (RTC) dismissed the complaint, ruling the allegation of “negotiations” did not equate to the statutory requirement of a “valid and definite offer.” It refused to consider the specific offer detailed in the City’s opposition, adhering to the rule that a motion to dismiss based on lack of cause of action must be resolved solely on the basis of the complaint’s allegations. The Court of Appeals affirmed this dismissal.
ISSUE
Whether the RTC and the Court of Appeals erred in dismissing the expropriation complaint for failure to state a cause of action based on a rigid, technical reading of the pleading.
RULING
Yes. The Supreme Court reversed the lower courts’ decisions. The Court held that the primordial concern of procedural rules is to secure substantial justice, not to override it through technicality. While the complaint’s allegation of “repeated negotiations” was arguably ambiguous, it was sufficient to constitute a statement of a cause of action. A cause of action exists if, hypothetically admitting the facts in the complaint, the court can render a valid judgment in favor of the plaintiff. The allegation of failed negotiations, in the context of an expropriation case, implies an attempt to reach an agreement, which inherently includes the making of an offer.
The Court criticized the lower courts’ overly strict application of the rule confining the evaluation to the four corners of the complaint. This technical approach deprived the City of its day in court to present evidence, such as the specific P478,000 offer detailed in its opposition, which would have clearly proven compliance with the statutory condition precedent. The rules of procedure should be liberally construed to afford parties a full hearing on the merits, especially where the defect is not incurable. The case was remanded to the RTC for trial on the merits.