GR 189311; (December, 2010) (Digest)
G.R. No. 189311; December 6, 2010
DENNIS R. MANZANAL and BAGUIO COUNTRY CLUB CORPORATION, Petitioners, vs. RAMON K. ILUSORIO, Respondent.
FACTS
Respondent Ramon K. Ilusorio, a member of the Baguio Country Club Corporation (BCCC), was assigned a penthouse unit. After a family conflict in 1998, he alleged he was barred from using the unit and faced near-expulsion. In 2001, BCCC, through its Assistant Vice President Dennis R. Manzanal, sent Ilusorio a statement of account demanding payment of ₱2,928,223.26 for alleged accumulated charges, including guest fees from 1995-1999 and rectification costs. Ilusorio contested the demand, claiming it was baseless and part of a harassment scheme orchestrated by his estranged siblings through Manzanal and BCCC.
Ilusorio filed a complaint for damages before the Makati RTC, seeking to enjoin the collection and claiming moral damages. He argued the charges had no legal basis, were prescribed, and that the demand letters were abusive acts done in bad faith. Manzanal filed a Motion to Dismiss for failure to state a cause of action, arguing that sending a demand letter is a legitimate act and that he, as a corporate officer, should not be held personally liable.
ISSUE
Whether the complaint for damages filed by Ilusorio states a cause of action against petitioners Dennis R. Manzanal and Baguio Country Club Corporation.
RULING
No, the complaint fails to state a cause of action. The Supreme Court reversed the Court of Appeals and reinstated the RTC’s order of dismissal. A cause of action exists only if the complaint alleges a legal right of the plaintiff, a correlative obligation of the defendant, and an act or omission by the defendant in violation of that right. The Court found that the act complained of—the sending of demand letters—is, by itself, a legitimate exercise of a right. A demand letter is a mere preliminary step to judicial or extrajudicial remedies and does not constitute actionable wrong. For a cause of action to arise from such an act, the complaint must sufficiently allege that the demand was so patently baseless, abusive, or malicious that it transgressed the limits of one’s right and violated the standards of human conduct under Articles 19, 20, or 21 of the Civil Code.
Ilusorio’s complaint merely contained general allegations of harassment and bad faith without asserting specific, concrete facts demonstrating how the mere act of demanding payment, even if disputed, was done in a manner that was wanton, oppressive, or amounted to an abuse of right. His defenses—such as prescription, laches, and lack of basis for the charges—are matters of defense that must be raised in an answer and proven during trial; they do not, by themselves, convert a lawful preliminary demand into an actionable wrong. Consequently, the allegations in the complaint were insufficient to constitute a cause of action for damages.