G.R. No. 252467 , June 21, 2021
Frank Colmenar, in his capacity as an heir of the late Francisco Colmenar, Petitioner, vs. Apollo A. Colmenar, Jeannie Colmenar Mendoza, Victoria Jet Colmenar, Philippine Estates Corporation, Amaia Land Corporation, Crisanta Realty Development Corporation, Property Company of Friends, and the Register of Deeds of the Province of Cavite, Respondents.

FACTS

Petitioner Frank Colmenar filed a complaint for declaration of nullity of deeds of extrajudicial settlement of estate, deeds of sale, cancellation of titles, and damages. He alleged being a legitimate son of the late Francisco Jesus Colmenar. Upon his father’s death, he learned that respondents Apollo Colmenar, Jeannie Colmenar Mendoza, and Victoria Jet Colmenar executed extrajudicial settlements of estate making it appear they were the sole surviving heirs, thereby allocating unto themselves Francisco’s interests in several Cavite properties. These individual respondents subsequently sold the properties to respondent corporations: Property Company of Friends (ProFriends), Crisanta Realty Development Corporation (Crisanta Realty), and Philippine Estates Corporation (PEC). PEC later sold one property to Amaia Land Corporation (Amaia). Petitioner claimed these sales deprived him of his successional rights.
The Regional Trial Court (RTC) initially denied the motions to dismiss and motions to hear affirmative defenses filed by the corporate respondents. However, after the 2019 Amendments to the Rules of Civil Procedure took effect, the RTC issued an Order dated May 22, 2020, dismissing the complaint against PEC, Amaia, Crisanta Realty, and ProFriends on the ground of failure to state a cause of action. The RTC applied Section 12, Rule 8 of the 2019 Amendments, resolving the affirmative defense of failure to state a cause of action motu proprio. It ruled that the complaint nowhere alleged that the corporate respondents were purchasers in bad faith or had notice of any defect in the titles of their vendors, and considered them innocent purchasers for value.

ISSUE

Whether the Regional Trial Court erred in dismissing the complaint against the corporate respondents (PEC, Amaia, Crisanta Realty, and ProFriends) on the ground of failure to state a cause of action.

RULING

Yes, the Supreme Court reversed and set aside the RTC’s Order. The complaint sufficiently stated a cause of action against the corporate respondents. A cause of action exists if the complaint alleges: (1) a legal right of the plaintiff, (2) a correlative obligation of the defendant, and (3) an act or omission of the defendant in violation of said legal right. Petitioner’s complaint alleged his right as a legitimate heir to his father’s estate, the corporate respondents’ obligation to respect that right as purchasers of the estate properties, and their act of purchasing the properties through void deeds of extrajudicial settlement executed by persons falsely claiming to be the sole heirs. The complaint’s ultimate basis is the alleged nullity of the extrajudicial settlements and the subsequent derivative sales. An action to declare the nullity of a void contract does not prescribe. The defense of being an innocent purchaser for value is a matter of evidence best threshed out during a full-blown trial, not a ground for a motion to dismiss based on failure to state a cause of action. The RTC’s reliance on the 2019 Amendments was misplaced as the provision on motu proprio resolution of affirmative defenses applies prospectively, and the court had already issued a prior order denying the motions to dismiss. The Supreme Court reinstated the complaint and directed the trial court to proceed with the case.