GR 152526; (November, 2004) (Digest)
G.R. No. 152526 November 25, 2004
RAMON R. JIMENEZ JR. and ANNABELLE L. JIMENEZ, petitioners, vs. JUAN JOSE JORDANA, respondent.
FACTS
Respondent Juan Jose Jordana offered to buy a property from Madeliene Bunye for P12.3 million, which Bunye accepted via letter dated December 28, 1993. Jordana attempted to remit the earnest money, but Bunye refused it and withdrew her acceptance, later demanding a higher price. Unbeknownst to Jordana, Bunye had already executed a Special Power of Attorney authorizing Lourdes Cuerva to sell the property. Cuerva subsequently entered into a Contract to Sell with petitioners Ramon and Annabelle Jimenez for P14.35 million. The Jimenez spouses made a downpayment and annotated an adverse claim on the title.
Jordana filed a complaint for Specific Performance and Damages against Bunye, alleging a perfected contract of sale. The Jimenez spouses intervened, and Jordana filed a Supplement to his Amended Complaint, impleading the spouses and seeking the annulment of their Contract to Sell with Bunye, the cancellation of the title issued to them, and the execution of a deed of sale in his favor. The trial court dismissed the Supplement for failure to state a cause of action against the Jimenez spouses, ruling that Jordana’s action was solely against Bunye.
ISSUE
Whether the Court of Appeals erred in reversing the trial court’s dismissal and in holding that the Supplement to Amended Complaint stated a cause of action against the petitioner-spouses Jimenez.
RULING
The Supreme Court affirmed the Court of Appeals, ruling that the Supplement did state a cause of action against the Jimenez spouses. A cause of action exists if the pleading alleges an act or omission by the defendant violating a right of the plaintiff. The Court emphasized that the cause of action is determined from the allegations in the complaint, and ambiguities may be clarified by examining its annexes and related pleadings.
The logic proceeds from Jordana’s core allegation: he had a prior perfected contract of sale with Bunye. From this premise, his subsequent allegations—that the Jimenez spouses contracted with Bunye despite knowledge of his claim, as evidenced by the annotated adverse claim they sought to cancel—logically seek relief against them as indispensable parties. His prayer for annulment of their contract and cancellation of their title is a direct consequence of asserting his superior right under his prior agreement. The trial court erred in isolating the allegations; a reading of the entire Supplement, in context with the annexed documents, sufficiently alleges a cause of action for the annulment of the subsequent sale to the Jimenez spouses to protect Jordana’s contractual rights. The case was remanded for trial on the merits.