When is statement of cause of action sufficient? - G.R. No. 152272

G.R. No. 152272

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Section 2, Rule 2 of the Rules of Court defines a cause of action as an act or omission by which a party violates the right of another. A complaint states a cause of action when it contains three (3) essential elements of a cause of action, namely:

(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.[18]

The question of whether the complaint states a cause of action is determined by its averments regarding the acts committed by the defendant.[19]  Thus, it must contain a concise statement of the ultimate or essential facts constituting the plaintiff’s cause of action.[20]  To be taken into account are only the material allegations in the complaint; extraneous facts and circumstances or other matters aliunde are not considered.[21]  

The test of sufficiency of facts alleged in the complaint as constituting a cause of action is whether or not admitting the facts alleged, the court could render a valid verdict in accordance with the prayer of said complaint.[22]Stated differently, if the allegations in the complaint furnish sufficient basis by which the complaint can be maintained, the same should not be dismissed regardless of the defense that may be asserted by the defendant.[23]

In the present case, the Court finds the allegations in the complaint sufficient to establish a cause of action. First, JCHA, et al.’s averments in the complaint show a demandable right over La Paz Road. These are: (1) their right to use the road on the basis of their allegation that they had been using the road for more than 10 years; and (2) an easement of a right of way has been constituted over the said roads. There is no other road as wide as La Paz Road existing in the vicinity and it is the shortest, convenient and safe route towards SLEX Halang that the commuters and motorists may use. Second, there is an alleged violation of such right committed by Fil-Estate, et al. when they excavated the road and prevented the commuters and motorists from using the same. Third, JCHA, et al. consequently suffered injury and that a valid judgment could have been rendered in accordance with the relief sought therein. 

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