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CONCEPCION V. VDA. DE DAFFON v. CA

FACTS:

FACTS

Concepcion Villamor was married to Amado Daffon and they had a son named Joselito Daffon. Joselito married Lourdes Osmeña and they had six children together. Amado passed away in 1982, and Joselito died in 1990. In 1994, Lourdes and her children filed a case against Concepcion seeking the partition of properties allegedly left by Amado that were part of his conjugal partnership with Concepcion. They claimed that Joselito, as a forced heir of Amado, was entitled to at least half of the estate. However, the properties were not divided, and after Joselito's death, Concepcion claimed absolute ownership and deprived Lourdes and her children of their rightful share. Lourdes and her children then sought the court's intervention for the partition of the conjugal properties. Concepcion filed a motion to dismiss the case, but the trial court denied it. Concepcion then filed a petition for certiorari with the Court of Appeals, but her petition was also denied. This led to the case being elevated to the Supreme Court, where Concepcion filed a petition for review.

ISSUES:

  1. Whether the trial court erred in denying petitioner's motion to dismiss the complaint for lack of jurisdiction and failure to state a cause of action.

  2. Whether the Court of Appeals erred in holding that private respondents need not be acknowledged as heirs of the deceased Amado Daffon.

  3. Whether the Court of Appeals erred in holding that it is not necessary for private respondents to be the registered owners of the properties claimed in the action for partition.

  4. Whether the Court of Appeals erred in holding that the trial court is not required to take judicial notice of another case pending in another court.

  5. Whether the Court of Appeals erred in not holding that the trial court's denial of petitioner's motion to dismiss the complaint based on failure to state a cause of action is reviewable by the special civil action of certiorari.

RULING:

  1. The court ruled that there is no merit in the petition. The court held that in determining whether a complaint fails to state a cause of action, only the statements in the complaint may be properly considered. A defendant who moves to dismiss the complaint on the ground of lack of cause of action hypothetically admits all the averments in the complaint. The test of sufficiency of the facts found in a complaint as constituting a cause of action is whether or not admitting the facts alleged, the court can render a valid judgment in accordance with the prayer. In this case, the complaint sufficiently alleged the relationship between the parties and the entitlement of the respondents as legitimate heirs of the deceased. The court further held that the issues raised by the petitioner can be addressed during a full-blown trial.

PRINCIPLES:

  • In determining whether a complaint fails to state a cause of action, only the statements in the complaint may be properly considered.

  • A defendant who moves to dismiss a complaint on the ground of lack of cause of action hypothetically admits all the averments in the complaint.

  • The test of sufficiency of the facts found in a complaint as constituting a cause of action is whether or not, admitting the facts alleged, the court can render a valid judgment in accordance with the prayer.

  • The issues raised by the defendant can be addressed during a full-blown trial.