Name: Talver M.

Villa

Civil Procedure: Liberal Construction of Rules of Court

(Doctrine of Administrative Remedies)

1. Pio Delos Reyes Vs. Flores,

G.R. No. 168726, March 5, 2010

Facts :
Pio delos Reyes, applied for exclusion from the coverage of operation land transfer, under
Presidential Decree (P.D.) No. 27. In 1988, Pio and his children, Fidel, Mauro, and Irene, executed a deed
of extrajudicial partition, which included the properties subject of the application for exclusion or retention.
In the proceedings for his application for exclusion or retention, Pio failed to submit vital documents such
as the deed of extrajudicial partition. Thus, the Department of Agrarian Reform (DAR) placed the subject
landholdings within the coverage of P.D. No. 27 and LOI No. 474. The DAR Secretary ruled that Pio and
his children actually owned landholdings used for residential, commercial, industrial, or other urban
purposes from which they derived adequate income, as evidenced by certifications issued by the Office of
the Provincial Assessor of Bataan and the various certificates of title submitted on record.
Pios heirs appealed to the Office of the President but was dismissed for being filed out of time.
They afterwards filed a petition for relief but was also denied. Afterwards, they filed an appeal in the Court
of Appeals but was also dismissed due to failure to exhaust the administrative remedies available from the
dismissal of their petition for relief.
Issue :
WON the Court of Appeals erred when it dismissed for prematurity the petition for certiorari and
mandamus filed by petitioners (Pio and his heirs).
Ruling:
We agree with the Court of Appeals that petitioners ignored the procedural requirement of filing a
motion for reconsideration and simply went ahead with the filing of a petition for certiorari and mandamus.
The thrust of the rule on exhaustion of administrative remedies is that courts must allow administrative
agencies to carry out their functions and discharge their responsibilities within the specialized areas of their
respective competence. It is true that litigation is not a game of technicalities, but it is equally true that
every case must be prosecuted in accordance with the prescribed procedure to insure an orderly and speedy
administration of justice. The procedural shortcut taken by petitioners finds no justification either in law or
in jurisprudence.
Name: Talver M. Villa

Civil Procedure: Cause of Action

2. Santos vs Spouses Pablo

G.R. No. 140892, September 21, 2005

Facts:
Spouses Pablo et. al ., herein respondents, filed a complaint for forcible entry against Josefina
Rivera in the MTC. In her answer, petitioner Rivera claimed that the real owner of the subject property is
Dr. Ibarra Santos, also a petitioner. The MTC and RTC decided in favor of the herein respondents.

Subsequently, Dr. Ibarra Santos and Josefina Rivera filed with the RTC, Paraaque City a Civil
Case for declaration of nullity of a Deed of Sale with prayer for a temporary restraining order and
preliminary injunction. Impleaded as defendants were spouses Pablo and Nieves de Leon (herein
respondents), Virginia Enales and Pericles Telan, deputy sheriff IV of the said MTC. The complaint alleges
that petitioner, Dr. Ibarra Santos, is the registered owner of a parcel of land. Respondent herein filed a
motion to dismiss the complaint on the ground that it states no cause of action. The motion was granted.

Issue:

WON the Court of Appeals erred in ruling that the complaint states no cause of action.

Ruling:

Yes, the CA erred in ruling that the petitioners does not have a cause of action. As the registered
owner of the subject property evidenced by a valid Certificate of Title, he has a cause of action against
spouses de Leon who claim to have purchased the same from Virginia Enales and Rosendo Rivera who are
not the true owners thereof.

In determining whether the allegations of the complaint are sufficient to support a cause of action,
the complaint does not have to establish or allege the facts proving the existence of a cause at the outset;
this will have to be done at the trial on the merits of the case.A complaint is sufficient if it contains sufficient
notice of the cause of action even though the allegations may be vague and indefinite. 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.

The general rule is that the allegations in a complaint are sufficient to constitute a cause of action
against the defendants if, admitting the facts alleged, the court can render a valid judgment upon the same
in accordance with the prayer therein. A cause of action exists if the following elements are present, namely:
(1) a right in favor of the plaintiff by whatever means and under whatever law it arises or is created; (2) an
obligation on the part of the named defendant to respect or not to violate such right; and (3) an act or
omission on the part of such defendant violative of the right of the plaintiff or constituting a breach of the
obligation of the defendant to the plaintiff for which the latter may maintain an action for recovery of
damages.
Name: Talver M. Villa

Civil Procedure: Parties

3. MIAA vs Rivera Village Lessee Homeowners Association

G.R. No. 143870,September 30, 2005

Facts:
On May 25, 1965, the (Civil Aeronautics Administration) CAA, in charge with the development of
Manila International Airport Authority (MIAA), through its Director, Capt. Vicente C. Rivera, entered into
individual lease contracts with its employees (lessees) for the lease of portions of a four (4)-hectare lot
situated in what is now known as Rivera Village. On May 4, 1982, Executive Order No. (EO) 778 was
issued (later amended by EO 903 on July 21, 1983), creating petitioner MIAA, transferring existing assets
of the MIA to MIAA, and vesting the latter with the power to administer and operate the MIA.
Sometime in January 1995, MIAA stopped issuing accrued rental bills and refused to accept rental
payments from the lessees. As a result, respondent Rivera Village Lessee Homeowners Association, Inc.
(homeowners association), purportedly representing the lessees, requested MIAA to sell the subject
property to its members, invoking the provisions of Presidential Decree No. (PD) 1517 or the Urban Land
Reform Act and PD 2016.
Respondent then filed a petition for mandamus and prohibition with prayer for the issuance of a
preliminary injunction against MIAA. MIAA filed an answer alleging that the petition fails to state a cause
of action in view of the expiration of the lease contracts and the lack of personality to sue of the homeowners
association.
The prayer for the issuance of a temporary restraining order and/or writ of preliminary injunction
is hereby denied for lack of merit. Respondent appealed but the RTC ruled that the petition failed to state a
cause of action inasmuch as petitioner therein (respondent homeowners association) is not the real party-
in-interest, the individual members of the association being the ones who have possessory rights over their
respective premises.
The CA declared that it cannot make a definitive ruling on the rights of the members of the
homeowners association vis--vis the MIAA Conceptual Development Plan, considering the need for a full-
blown trial to ferret out whether the claimed rights under the pertinent laws have ripened to actual legal and
vested rights in their favor.
Issue:
WON the respondent has personality to sue.
Ruling:

No, the respondent has no personality to sue. MIAA contends that the real parties-in-interest in the
petition filed with the trial court are the individual members of the homeowners association. Not having
been brought in the name of the real parties-in-interest, the suit was correctly dismissed by the trial court
for failure to state a cause of action.
 The 1997 Rules of Civil Procedure (Rules of Court) requires that every action must be prosecuted
or defended in the name of the real party-in-interest, i.e., the party who stands to be benefited or injured by
the judgment in the suit, or the party entitled to the avails of the suit. A case is dismissible for lack of
personality to sue upon proof that the plaintiff is not the real party-in-interest, hence grounded on failure to
state a cause of action.

Obviously, the petition cannot be considered a class suit under Sec. 12, Rule 3 of the Rules of Court,
the requisites therefor not being present in the case, notably because the petition does not allege the
existence and prove the requisites of a class suit, i.e., that the subject matter of the controversy is one of
common or general interest to many persons and the parties are so numerous that it is impracticable to bring
them all before the court, and because it was brought only by one party.
Name: Talver M. Villa
Civil Procedure: Parties
4. Pascual vs Robles
G.R. No. 182645, December 15, 2010

Facts:
A petition for Declaration of Heirship and Appointment of Administrator and Settlement of the
Estates of the Late Hermogenes Rodriguez (Hermogenes) and Antonio Rodriguez (Antonio) was filed
before the RTC. Henry, Certeza and Rosalina sought that they be declared the sole and surviving heirs of
the late Antonio Rodriguez and Hermogenes Rodriguez. They alleged they are the great grandchildren of
Antonio.

Six groups of oppositors entered their appearances either as a group or individually, one including
Jaime Robles. In his opposition, Jamie Robles likewise prayed that he be appointed regular administrator
to the estates of Antonio and Hermogenes and be allowed to sell a certain portion of land included in the
estate of Hermogenes covered located at Barrio Manggahan, Pasig, Rizal. After hearing on Jamie Robles'
application for appointment as regular administrator, the RTC issued an Order declaring him to be an heir
and next of kin of decedent Hermogenes.

On 13 August 1999, the RTC issued an Amended Decision reversing its earlier finding. The RTC
dismissed the opposition of Robles. Robles then appealed the August 13, 1999 Decision of the RTC by
filing a Notice of Appeal, but the same was denied by the trial court in its Order dated November 22, 1999
for Robles' failure to file a record on appeal. Robles questioned the denial of his appeal by filing a petition
for review on certiorari with this Court. The basic contention of Robles in the instant Motion is that he is a
party-in-interest who stands to be adversely affected or injured or benefited by the judgment in the instant
case.
Pascual, the petitioner, contends that Robles has no legal standing to participate in the instant
petition.

Issue:

WON Robles is an indispensable party and his failure to be impleaded is a valid ground for the
dismissal of an action.

Ruling:

In the case at bar, Robles is an indispensable party. He stands to be injured or benefited by the
outcome of the petition. He has an interest in the controversy that a final decree would necessarily affect
his rights, such that the courts cannot proceed without his presence. Moreover, as provided for under the
aforequoted Section 5, Rule 65 of the Rules of Court, Robles is interested in sustaining the assailed CA
Decision, considering that he would benefit from such judgment. As such, his non-inclusion would render
the petition for certiorari defective. Petitioner, thus, committed a mistake in failing to implead Robles as
respondent.
Name: Talver M. Villa
Civil Procedure: Venue

5. Nocum and PDI vs Lucio Tan

G.R. No. 145022, September 23, 2005

Facts:
Lucio Tan filed a complaint against reporter Armand Nocum, Capt. Florendo Umali, ALPAP and
Inquirer with the Regional Trial Court of Makati, seeking moral and exemplary damages for the alleged
malicious and defamatory imputations contained in a news article.

Inquirer et al then filed their joint answer alleging that the complaint failed a to state a cause of
action and venue was improperly laid, among others. The RTC dismissed the case for improper venue at
first but then set aside the said order after an Omnibus Motion filed by Lucio Tan.

Issue:

WON lower court acquire jurisdiction over the civil case upon the filing of the original complaint
for damages.

Ruling:

Yes, the RTC acquired jurisdiction over the subject matter upon the filing of the original complaint.
It did not lose jurisdiction over the same when it dismissed it on the ground of improper venue. The
amendment merely laid down the proper venue of the case.

It is settled that jurisdiction is conferred by law based on the facts alleged in the complaint since
the latter comprises a concise statement of the ultimate facts constituting the plaintiff's causes of action. In
the case at bar, after examining the original complaint, we find that the RTC acquired jurisdiction over the
case when the case was filed before it. From the allegations thereof, respondents cause of action is for
damages arising from libel, the jurisdiction of which is vested with the RTC. Article 360 of the Revised
Penal Code provides that it is a Court of First Instance that is specifically designated to try a libel case.

In the case at bar, the additional allegations in the Amended Complaint that the article and the
caricature were printed and first published in the City of Makati referred only to the question of venue and
not jurisdiction. These additional allegations would neither confer jurisdiction on the RTC nor would
respondents failure to include the same in the original complaint divest the lower court of its jurisdiction
over the case. Respondents failure to allege these allegations gave the lower court the power, upon motion
by a party, to dismiss the complaint on the ground that venue was not properly laid.