When can a court dismiss a civil case for failure to state a cause of action?

The Supreme Court (SC) said a cause of action exists when a legal right is violated. It stressed that courts cannot hear a civil case unless there is cause of action.

In a decision written by Associate Justice Maria Filomena D. Singh and posted in the SC website – sc.judiciary.gov.ph – on Friday, March 27, the SC said a case may be dismissed if the complaint does not state a cause of action.

In determining if a complaint fails to state a cause of action, a court should look only at what is written in the complaint and assume the allegations are true.

However, even assuming the facts are true, a court still cannot grant the relief sought and it can dismiss the complaint on the ground of failure to state a cause of action.

It clarified that failure to state a cause of action may still be raised as an affirmative defense in the answer under Section 12(4), Rule 8 of the Rules of Court.

On the contrary, the SC pointed out that to determine whether a case lacks a cause of action, the court should look at the evidence presented.

It said that a confusion arose from past rulings that allowed courts, in some instances, to look beyond the complaint, such as when the allegations appear to be legally impossible or unfounded.

It added the previous rulings blurred the difference between failure to state a cause of action and lack of cause of action.

Now, the SC ruled that courts may dismiss a complaint for failure to state a cause of action only by examining the complaint and its attachments -- nothing more. It stressed that courts must not consider other pleadings or submissions at this stage.

“Once the trial court considers other pleadings submitted by the parties or evidence admitted during the proceedings, it is no longer determining a failure to state a cause of action, but rather the very existence of one. In doing so, the ground for dismissing the complaint or petition ceases to be ‘failure to state a cause of action’ and becomes ‘lack of cause of action,’” the SC said

The SC’s decision stemmed from a petition filed by a party in the case involving a land dispute between the groups of Inocencio Taganile and Filomena Delos Santos Dolar.

Taganile’s group claimed that it has occupied a portion of land along Dr. Sixto Antonio Avenue in Rosario, Pasig City, since 1970.

When Taganile’s group learned that the land had been registered in the name of Dolar’s group, the former filed a petition before the Regional Trial Court (RTC) to challenge the title.

Dolar’s group, on the other hand, claims that Taganile’s group were mere lessees. It then filed a motion to dismiss the petition and alleged that the petition did not state a cause of action because it lacked supporting documents.

In 2019, the RTC dismissed the case filed by Taganile’s group after considering both the petition and the evidence presented by Dolar’s group.

The trial court ruled that the case failed to state a cause of action because it did not include proof of the group of Taganile on the claim to the land.

The Court of Appeals (CA) affirmed in 2021 the RTC’s decision.

Taganile’s group elevated the issue before the SC after the CA affirmed in a 2022 resolution its 2021 decision.

The SC reversed the CA decision and ordered the remand of the case to the RTC to continue the proceedings and receive evidence on the parties’ claims.

It ruled that the RTC and CA improperly relied on the submissions and evidence of Dolar’s group.

It said that the two courts prematurely ruled on the existence of a cause of action without giving Taganile’s group the chance to present evidence.

It also said that based on the allegations alone, the petition was able to establish a case for quieting of title as it noted Taganile group’s claims of long-standing possession and houses built on the property since the 1970s.

The SC said:

“In resolving whether a party failed to state a cause of action, courts must be careful not to conflate this inquiry with a determination of whether the party actually has a cause of action. The former is a procedural question confined to the pleading, while the latter is a substantive issue that necessarily entails the reception and evaluation of evidence.

“When a court admits and relies on matters outside the pleading, it effectively shifts from assessing the sufficiency of the allegations to ruling on the merits of the claim itself.

“Fair play requires that the sufficiency of an initiatory pleading be determined solely from the plaintiff's own allegations and statements in their complaint or petition. The determination should not hinge on the submissions of other parties, as this would unjustly bind one party to matters clearly beyond their control.

“In the end, the truth of conflicting allegations is best resolved through trial, not by a cursory invocation of the exceptions that the Court now reexamines.”