San Lorenzo Village Association, Inc. vs.

CA
Petitioner: San Lorenzo Village Assoc. , Inc. (SLVAI)
Respondent: Hon Judge Diokno and Almeda Development &
Equipment Corporation (ADEC)
Date:
DOCTRINE
Ground for dismissal of a complaint is not lack or absence of
cause of action BUT that the complaint states NO cause of action.

A complaint states a cause of action where it contains the 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.
Absence of 3 elements = No cause of action = complaint
vulnerable to a motion to dismiss.

FACTS
1. Almeda owned land and bldg. in Pasay Road, San Lorenzo
Village, Makati TCT 4738
2. TCT contained restriction on ownership imposed in 1958
a. Automatic membership in SLVAI
b. Lot may not be subdivided
c. To be used for residential purposes only
d. Only 1 storey bldg. may be erected
e. There must be an easement
3. Land was sold to ADEC in 1990. ADEC wanted to cancel the
annotations. Co. assailed restrictions in the TCT as Pasay Road is
already filled with commercial establishments/ industrial buidlings.
4. ADEC wanted to build a taller building and DID NOT WANT TO
BECOME SLVA member
5. ADEC filed petition for TRO and prohibition against SLVAI and
prayed to cancel the annotations
6. SLVAI filed motion to dismiss on grounds of LACK OF CAUSE OF
ACTION and lack of ADECs personality to sue.
7. Court denied SLVAIs motion. CA also denied certiorari

8. Hence this petition for certiorari filed by SLVAI to SC

ISSUE/S
1. W/N Almeda Devt and Equipment Corporation (ADEC) has a
cause of action.
HELD/RATIO
1. YES, ADEC has a cause of action.
When a complaint states a cause of action
A complaint states a cause of action where it contains the 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.
If these elements are absent, the complaint becomes vulnerable to a
motion to dismiss on the ground of failure to
state a cause of action.
The averments in the complaint are allegations well within the
hypothetical-admission principle.
Here, the averments in the complaint like the title of ADECs vendor,
the execution of the sale by said vendor to ADEC, the latters status as
the vendors successor-in-interest, and the altered physical
environment along Pasay Road, are allegations well within the
hypothetical-admission principle. These averments satisfy the three
(3) elements of a cause of action. In other words, the complaint
did state a cause of action.
SC DECISION: Petition by SLVAI Dismissed. CA Decision
Affirmed.