G.R. No. L-28996 September 30, 1982
MAXIMO SANTOS, ET AL., plaintiffs-appellants, vs. GENERAL WOODCRAFT AND DESIGN CORPORATION, ROMEO GONZALES and NESTOR MARFORI, defendants-appellees.

FACTS

On November 3, 1966, plaintiffs-appellants, employees of General Woodcraft and Design Corporation, filed a complaint in the Court of First Instance of Rizal against the corporation and its officers for collection of separation pay, overtime compensation, and vacation and sick leave benefits. They alleged their services were terminated without just cause on October 3, 1966. Defendants-appellees, in their answer, contended the business operations were merely suspended and asserted that the claims constituted labor disputes falling under the exclusive jurisdiction of the Court of Industrial Relations, not the Court of First Instance.
During the pre-trial conference on August 9, 1967, the trial court noted the complaint lacked clear and categorical allegations to substantiate the claims for overtime pay and leave benefits. The court ordered plaintiffs’ counsel to file a motion to amend the complaint within ten days. Plaintiffs failed to comply with this order. Subsequently, on September 14, 1967, defendants moved to dismiss the complaint for failure to state a cause of action. The trial court granted the motion and dismissed the complaint in an order dated September 16, 1967, prompting this appeal.

ISSUE

Whether the trial court correctly dismissed the complaint for failure to state a cause of action due to plaintiffs’ non-compliance with the court’s order to amend their pleading.

RULING

The Supreme Court affirmed the order of dismissal but modified its effects. The Court meticulously scrutinized the complaint and agreed with the trial court’s observation that it was unskillfully drafted and deficient in material factual details for each claim. However, this deficiency did not constitute a failure to state a cause of action. A complaint states a cause of action if it contains sufficient allegations of a right belonging to the plaintiff and a violation of that right by the defendant. The pleaded claims for separation and overtime pay, while vague, met this basic standard.
The proper remedy for the vagueness was an amendment to make the claims more definite or a motion for a bill of particulars, which the trial court correctly ordered. Since plaintiffs failed to comply with this lawful order within the given period, the trial court acted within its prerogative in dismissing the complaint pursuant to Section 3, Rule 17 of the Rules of Court, which allows dismissal for failure to comply with a court order. The dismissal was thus justified as a sanction for procedural non-compliance.
Nevertheless, the Supreme Court ruled that such dismissal should not operate as an adjudication on the merits to bar the employee-plaintiffs from further enforcing their rights. In the interest of justice, and considering the transfer of jurisdiction over such money claims to the Labor Arbiter under Presidential Decree No. 1691, the Court ordered that the dismissal be without prejudice to the plaintiffs’ right to refile their claims before the proper labor tribunal, without being barred by the statute of limitations.