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GR No. 201248

2015-03-11

LETICIA NAGUIT AQUINO v. CESAR B. QUIAZON

MENDOZA, J.

The Court does not discount, however, that there are exceptions to the general rule that allegations are hypothetically admitted as true and inquiry is confined to the face of the complaint. First, there is no hypothetical admission of (a) the veracity of allegations if their falsity is subject to judicial notice; (b) allegations that are legally impossible; (c) facts inadmissible in evidence; and (d) facts which appear, by record or document included in the pleadings, to be unfounded.[28] Second, inquiry is not confined to the complaint if culled (a) from annexes and other pleadings submitted by the parties;[29] (b) from documentary evidence admitted by stipulation which disclose facts sufficient to defeat the claim; or (c) from evidence admitted in the course of hearings related to the case.[30]

GR No. 201248

2015-03-11

LETICIA NAGUIT AQUINO v. CESAR B. QUIAZON

MENDOZA, J.

The Court does not discount, however, that there are exceptions to the general rule that allegations are hypothetically admitted as true and inquiry is confined to the face of the complaint. First, there is no hypothetical admission of (a) the veracity of allegations if their falsity is subject to judicial notice; (b) allegations that are legally impossible; (c) facts inadmissible in evidence; and (d) facts which appear, by record or document included in the pleadings, to be unfounded.[28] Second, inquiry is not confined to the complaint if culled (a) from annexes and other pleadings submitted by the parties;[29] (b) from documentary evidence admitted by stipulation which disclose facts sufficient to defeat the claim; or (c) from evidence admitted in the course of hearings related to the case.[30]

GR No. 204160

2014-09-22

SPS. MICHELLE M. NOYNAY AND NOEL S. NOYNAY v. CITIHOMES BUILDER

MENDOZA, J.

Cause of action has been defined as an act or omission by which a party violates a right of another.[12] It requires the existence of a legal right on the part of the plaintiff, a correlative obligation of the defendant to respect such right, and an act or omission of such defendant in violation of the plaintiff's rights.[13] A complaint should not be dismissed for insufficiency of cause of action if it appears clearly from the complaint and its attachments that the plaintiff is entitled to relief. [14] The complaint, however, may be dismissed for lack of cause of action later after questions of fact have been resolved on the basis of stipulations, admissions or evidence presented.[15]

GR No. 173987

2013-02-25

PADILLA MERCADO v. SPS. AGUEDO ESPINA

PERALTA, J.

Failure to state a cause of action refers to the insufficiency of the pleading, and is a ground for dismissal under Rule 16 of the Rules of Court.[17]

GR NO. 172242

2007-08-14

PERKIN ELMER SINGAPORE PTE LTD. v. DAKILA TRADING CORPORATION

CHICO-NAZARIO, J.

Dismissal of a Complaint for failure to state a cause of action is provided for by the Rules of Court.[44] When a Motion to Dismiss is grounded on the failure to state a cause of action, a ruling thereon should be based only on the facts alleged in the complaint. The court must pass upon this issue based solely on such allegations, assuming them to be true. For it to do otherwise would be a procedural error and a denial of plaintiff's right to due process.[45] While, truly, there are well-recognized exceptions[46] to the rule that the allegations are hypothetically admitted as true and inquiry is confined to the face of the complaint,[47] none of the exceptions apply in this case. Hence, the general rule applies. The defense of the petitioner that it is not the real party-in-interest is evidentiary in nature which must be proven in trial. The appellate court, then, cannot be faulted for not granting petitioner's Motion to Dismiss on the ground of failure to state a cause of action.

GR NO. 166403

2006-11-02

BENZON O. ALDEMITA v. HEIRS OF MELQUIADES SILVA

AUSTRIA-MARTINEZ, J.

In the case of Goodyear Phil., Inc. v. Sy,[20] the Court held that in determining whether an initiatory pleading states a cause of action, "the test is as follows: admitting the truth of the facts alleged, can the court render a valid judgment in accordance with the prayer?"[21] To be taken into account are only the material allegations in the complaint; extraneous facts and circumstances or other matters aliunde are not considered.[22] Stated otherwise, the test is whether the material allegations, assuming these to be true, state ultimate facts which constitute plaintiff's cause of action, such that plaintiff is entitled to a favorable judgment as a matter of law.[23] The general rule is that inquiry is confined to the four corners of the complaint, and no other.[24]

GR NO. 146818

2006-02-06

JAN-DEC CONSTRUCTION CORPORATION v. CA

AUSTRIA-MARTINEZ, J.

[24] Dabuco v. Court of Appeals, 379 Phil. 939 (2000).

GR No. 162461

2005-11-23

AMOS P. FRANCIA v. POWER MERGE CORPORATION

CARPIO MORALES, J.

A cause of action has three elements, to wit: (1) the legal right of the plaintiff, (2) the correlative obligation of the defendant, and (3) the act or omission of the defendant in violation of said legal right. In the determination of whether these elements are present, inquiry is generally confined to the four corners of the complaint and no other,[15] but the annexes attached to the complaint may be considered, they being parts thereof.[16]

GR No. 152526

2004-11-25

RAMON R. JIMENEZ JR. v. JUAN JOSE JORDANA

PANGANIBAN, J.

The Court must, however, emphasize the provisional nature of any ruling herein on the nature of the contract between respondent and Bunye, as we have premised such ruling only on the hypothetical admissions of petitioners' averments. Additionally, in determining that a cause of action exists against petitioners, the Court has necessarily inquired only into the sufficiency, not the veracity, of the material allegations.[50] The truth of those allegations, as well as petitioners' defenses, can be determined only after the parties have adduced their respective sets of evidence.

GR No. 126640

2000-11-23

SPS. MARCELO B. ARENAS AND ANITA T. ARENAS v. CA

PARDO, J.

A cause of action has the following elements: (1) the legal right of plaintiff, (2) the correlative obligation of the defendant, and (3) the act or omission of the defendant in violation of said legal right.[30]

	GR No. 201248 2015-03-11	LETICIA NAGUIT AQUINO v. CESAR B. QUIAZON MENDOZA, J.
The Court does not discount, however, that there are exceptions to the general rule that allegations are hypothetically admitted as true and inquiry is confined to the face of the complaint. First, there is no hypothetical admission of (a) the veracity of allegations if their falsity is subject to judicial notice; (b) allegations that are legally impossible; (c) facts inadmissible in evidence; and (d) facts which appear, by record or document included in the pleadings, to be unfounded.[28] Second, inquiry is not confined to the complaint if culled (a) from annexes and other pleadings submitted by the parties;[29] (b) from documentary evidence admitted by stipulation which disclose facts sufficient to defeat the claim; or (c) from evidence admitted in the course of hearings related to the case.[30]
	GR No. 201248 2015-03-11	LETICIA NAGUIT AQUINO v. CESAR B. QUIAZON MENDOZA, J.
The Court does not discount, however, that there are exceptions to the general rule that allegations are hypothetically admitted as true and inquiry is confined to the face of the complaint. First, there is no hypothetical admission of (a) the veracity of allegations if their falsity is subject to judicial notice; (b) allegations that are legally impossible; (c) facts inadmissible in evidence; and (d) facts which appear, by record or document included in the pleadings, to be unfounded.[28] Second, inquiry is not confined to the complaint if culled (a) from annexes and other pleadings submitted by the parties;[29] (b) from documentary evidence admitted by stipulation which disclose facts sufficient to defeat the claim; or (c) from evidence admitted in the course of hearings related to the case.[30]
	GR No. 204160 2014-09-22	SPS. MICHELLE M. NOYNAY AND NOEL S. NOYNAY v. CITIHOMES BUILDER MENDOZA, J.
Cause of action has been defined as an act or omission by which a party violates a right of another.[12] It requires the existence of a legal right on the part of the plaintiff, a correlative obligation of the defendant to respect such right, and an act or omission of such defendant in violation of the plaintiff's rights.[13] A complaint should not be dismissed for insufficiency of cause of action if it appears clearly from the complaint and its attachments that the plaintiff is entitled to relief. [14] The complaint, however, may be dismissed for lack of cause of action later after questions of fact have been resolved on the basis of stipulations, admissions or evidence presented.[15]
	GR No. 173987 2013-02-25	PADILLA MERCADO v. SPS. AGUEDO ESPINA PERALTA, J.
Failure to state a cause of action refers to the insufficiency of the pleading, and is a ground for dismissal under Rule 16 of the Rules of Court.[17]
	GR NO. 172242 2007-08-14	PERKIN ELMER SINGAPORE PTE LTD. v. DAKILA TRADING CORPORATION CHICO-NAZARIO, J.
Dismissal of a Complaint for failure to state a cause of action is provided for by the Rules of Court.[44] When a Motion to Dismiss is grounded on the failure to state a cause of action, a ruling thereon should be based only on the facts alleged in the complaint. The court must pass upon this issue based solely on such allegations, assuming them to be true. For it to do otherwise would be a procedural error and a denial of plaintiff's right to due process.[45] While, truly, there are well-recognized exceptions[46] to the rule that the allegations are hypothetically admitted as true and inquiry is confined to the face of the complaint,[47] none of the exceptions apply in this case. Hence, the general rule applies. The defense of the petitioner that it is not the real party-in-interest is evidentiary in nature which must be proven in trial. The appellate court, then, cannot be faulted for not granting petitioner's Motion to Dismiss on the ground of failure to state a cause of action.
	GR NO. 166403 2006-11-02	BENZON O. ALDEMITA v. HEIRS OF MELQUIADES SILVA AUSTRIA-MARTINEZ, J.
In the case of Goodyear Phil., Inc. v. Sy,[20] the Court held that in determining whether an initiatory pleading states a cause of action, "the test is as follows: admitting the truth of the facts alleged, can the court render a valid judgment in accordance with the prayer?"[21] To be taken into account are only the material allegations in the complaint; extraneous facts and circumstances or other matters aliunde are not considered.[22] Stated otherwise, the test is whether the material allegations, assuming these to be true, state ultimate facts which constitute plaintiff's cause of action, such that plaintiff is entitled to a favorable judgment as a matter of law.[23] The general rule is that inquiry is confined to the four corners of the complaint, and no other.[24]
	GR NO. 146818 2006-02-06	JAN-DEC CONSTRUCTION CORPORATION v. CA AUSTRIA-MARTINEZ, J.
[24] Dabuco v. Court of Appeals, 379 Phil. 939 (2000).
	GR No. 162461 2005-11-23	AMOS P. FRANCIA v. POWER MERGE CORPORATION CARPIO MORALES, J.
A cause of action has three elements, to wit: (1) the legal right of the plaintiff, (2) the correlative obligation of the defendant, and (3) the act or omission of the defendant in violation of said legal right. In the determination of whether these elements are present, inquiry is generally confined to the four corners of the complaint and no other,[15] but the annexes attached to the complaint may be considered, they being parts thereof.[16]
	GR No. 152526 2004-11-25	RAMON R. JIMENEZ JR. v. JUAN JOSE JORDANA PANGANIBAN, J.
The Court must, however, emphasize the provisional nature of any ruling herein on the nature of the contract between respondent and Bunye, as we have premised such ruling only on the hypothetical admissions of petitioners' averments. Additionally, in determining that a cause of action exists against petitioners, the Court has necessarily inquired only into the sufficiency, not the veracity, of the material allegations.[50] The truth of those allegations, as well as petitioners' defenses, can be determined only after the parties have adduced their respective sets of evidence.
	GR No. 126640 2000-11-23	SPS. MARCELO B. ARENAS AND ANITA T. ARENAS v. CA PARDO, J.
A cause of action has the following elements: (1) the legal right of plaintiff, (2) the correlative obligation of the defendant, and (3) the act or omission of the defendant in violation of said legal right.[30]

FIDEL DABUCO v. CA