Recitation-Ready Case Digest 9.
That in case the properties
G.A.M.L.P subject of the lease agreement is sold
or encumbered, Lessors shall impose
PARAÑAQUE KINGS ENTERPRISES, as a condition that the buyer or
INCORPORATED, Petitioner VS. COURT OF mortgagee thereof shall recognize
APPEALS, CATALINA L. SANTOS, REPRESENTED and be bound by all the terms and
BY HER ATTORNEY-IN-FACT, LUZ B. PROTACIO, conditions of this lease agreement
and shall respect this Contract of
AND DAVID A. RAYMUNDO, Respondents.
Lease as if they are the LESSORS
thereof and in case of sale, LESSEE
Doctrine: In determining the sufficiency of a
shall have the first option or
complaint to support a cause of action, the
complaint does not need to initially prove the priority to buy the properties
existence of a cause of action; this subject of the lease;
determination will occur during the trial on the
merits. To dismiss a complaint for lack of cause Defendant Santos sold the eight
of action, it must clearly show that no claim for parcels of land subject of the lease to
relief exists, rather than merely being Defendant David Raymundo, for a
ambiguous, indefinite, or defectively stated. consideration of P5 million, in contravention
Additionally, when a defendant moves to of the contract of lease, for the first option or
dismiss on this ground, they are deemed to priority to buy was not offered by defendant
hypothetically admit all allegations in the Santos to the plaintiff. Santos, realizing the
complaint solely for the purpose of resolving
error, she had it reconveyed to her for the
the motion. However, this hypothetical
admission does not deprive the defendant of same consideration of P5 million and
their right to present evidence and contest the subsequently the property was offered for
allegations at trial. The case should proceed to sale to plaintiff for the sum of P15 million,
trial to allow both parties to present their however the period of 10 days to make good
evidence, enabling the court to determine the of the offer expired and the petitioner
validity of the claims and apply the appropriate refused to buy the same because of
remedies. “ridiculous” price. Another deed of sale was
executed by Santos in favor of Raymundo
for consideration of P9 million. Hence, the
FACTS: petitioner filed a complaint before the RTC.
Defendant Catalina Santos is the Instead of filing their respective answers,
owner of 8 parcels of land located in respondents filed motions to dismiss which
Parañaque. Frederick Chua leased the the trial court had granted.
property of defendant and assigned all rights
and interest and participation in the leased The RTC dismissed the complaint for lack
property to Lee Ching Bing by deed of of a valid cause of action. It ratiocinated that
assignment. Lee Ching Bing also assigned upon the very face of the plaintiff’s
all his rights and interest in the leased complaint, Santos complied with the lease
property to Parañaque Kings Enterprises, agreement by offering the properties for sale
Inc. All of these contracts or deeds were to the plaintiff and there was a definite
registered. refusal on the part of the plaintiff to accept
the offer.
Paragraph 9 of the assigned leased
contract provides among others that:
CA affirmed in toto the ruling of RTC. ground of lack of cause of action is regarded
as having hypothetically admitted all the
The respondent alleged that the complaint averments thereof.
should be dismissed for not raising a
question of law as the issue involved is The court found that the complaint
purely factual. sufficiently alleged a breach of the lease
contract, which granted the petitioner the
ISSUE: first option to purchase the properties.
1. Whether or not the complaint states a Respondent Santos sold the properties to
valid cause of action. Raymundo without offering them to the
petitioner, violating this agreement. Though
2. Whether or not the complaint should be Santos repurchased the properties and later
dismissed for not raising a question of law offered them at an unreasonable price of P15
as the issue involved is purely factual. million, she resold them to Raymundo for
₱9 million without offering them to the
RULING: petitioner. Whether this breach entitles the
petitioner to damages or other relief requires
YES. In determining whether resolution at trial.
allegations of a complaint are sufficient to
support a cause of action, it must be borne in We do not agree with respondents'
mind that the complaint does not have to contention that the issue involved is purely
establish or allege facts proving the factual. The principal legal question, as
existence of a cause of action at the outset; stated earlier, is whether the complaint filed
this will have to be done at the trial on the by herein petitioner in the lower court states
merits of the case. a valid cause of action. Since such question
assumes the facts alleged in the complaint as
A cause of action exists if the following true, it follows that the determination thereof
elements are present: (1) a right in favor of is one of law, and not of facts. There is a
the plaintiff by whatever means and under question of law in a given case when the
whatever law it arises or is created; (2) an doubt or difference arises as to what the law
obligation on the part of the named is on a certain state of facts, and there is a
defendant to respect or not to violate such question of fact when the doubt or difference
right, and (3) an act or omission on the part arises as to the truth or the falsehood of
of such defendant violative of the right of alleged facts.
plaintiff or constituting a breach of the
obligation of defendant to the plaintiff for
which the latter may maintain an action for
recovery of damages.
To sustain a motion to dismiss for
lack of cause of action, the complaint must
show that the claim for relief does not exist,
rather than that a claim has been defectively
stated, or is ambiguous, indefinite or
uncertain. Equally important, a defendant
moving to dismiss a complaint on the
