G.R. No. 140892. September 21, 2005
Dr. Ibarra S. Santos and Josefina M. Rivera, Petitioners, vs. Spouses Pablo and Nieves de Leon and Virginia Enales, Respondents.

FACTS

Petitioners Dr. Ibarra Santos and Josefina Rivera filed a complaint for declaration of nullity of a Deed of Sale before the Regional Trial Court (RTC). Dr. Santos alleged he is the registered owner of a property, as evidenced by TCT No. 69150. The complaint stated that respondents Virginia Enales and the late Rosendo Rivera (husband of petitioner Rivera) sold this property to respondent spouses Pablo and Nieves de Leon. Petitioner Rivera, claiming to be a lessee of Dr. Santos since 1983, was evicted from the property pursuant to a writ of execution in a prior forcible entry case filed by the de Leon spouses.
Respondent spouses de Leon filed a motion to dismiss the complaint on the ground of failure to state a cause of action, which the RTC granted. The Court of Appeals affirmed, ruling that while the complaint alleged the Deed of Sale was null and void, it failed to specify the grounds for such nullity. Petitioners thus elevated the case to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of the complaint on the ground that it fails to state a cause of action.

RULING

Yes. The Supreme Court reversed the appellate court’s decision and reinstated the complaint. The Court held that a cause of action exists if the complaint alleges: (1) a right in favor of the plaintiff; (2) an obligation on the part of the defendant to respect that right; and (3) an act or omission by the defendant constituting a violation of that right. The complaint sufficiently alleged these elements.
Dr. Santos’s allegation of being the absolute registered owner of the property, supported by a copy of the title, establishes his right. The act of respondents Enales and Rivera in selling, and the de Leon spouses in purchasing, property they did not own constitutes an alleged violation of that ownership right. For her part, petitioner Rivera alleged a lessee’s right of possession since 1983, which was prejudiced by the sale and her subsequent eviction.
The complaint only needs to state ultimate facts, not detailed evidence or the specific legal grounds for nullity, which are matters for trial. A motion to dismiss based on lack of cause of action should be granted only if the complaint shows no claim for relief exists, not merely that the claim is defectively stated. The issue of ownership and the validity of the sale require a full trial on the merits. The case was remanded to the RTC for further proceedings.