G.R. No. 92029-30 - De Guzman, Jr. vs. Court of Appeals

A cause of action is defined as the fact or combination of facts that grants a party the right to seek judicial intervention.
An action refers to a legal suit in which one party seeks to enforce or protect a right or to seek redress for a wrong.
The cause of action consists of two essential elements:
1. The plaintiff's primary right and the defendant's corresponding primary duty.
2. The wrongful act or omission by the defendant that violates the primary right and duty.
The determination of a cause of action is based on the facts alleged in the complaint, not merely on the prayer for relief.
The right of action is the entitlement to initiate and maintain a legal action, distinct from the cause of action, which is a formal statement of the facts that give rise to that right.

The right of action is a remedial right belonging to individuals, while the cause of action is a formal statement of operative facts.
The right of action is governed by substantive law, whereas the cause of action is governed by procedural law.
A right of action arises from a cause of action but does not exist until all facts constituting the cause of action have occurred.
Legal remedies become operative only upon the invasion of primary rights, which necessitates a violation of a legal right.

The petitioner filed a complaint for damages and equitable relief in the Regional Trial Court of Manila on September 15, 1988.
The complaint detailed a long-standing friendship between the petitioner and the respondent, involving the exchange of checks for cash.
The petitioner alleged that several checks totaling P280,900.00 were issued to the respondent, which had been settled or condoned by mutual agreement.
A demand letter from the respondent's lawyer claimed a total amount due of P568,541.00, which the petitioner contested as not being due.

The petitioner claimed that the demand letter threatened legal action for an obligation that was not due, causing him injury.
The respondent was accused of unlawfully withholding the checks, which should be returned to the petitioner.
The petitioner sought actual damages, exemplary damages, nominal damages, and the return of the checks, along with attorney's fees and costs of the suit.

The respondent filed a motion to dismiss the complaint, citing lack of cause of action and prescription.
The trial court dismissed the complaint on November 24, 1988, for failure to state a cause of action.
A motion for reconsideration was denied, leading the petitioner to file a petition for certiorari and mandamus in the Court of Appeals.
The Court of Appeals dismissed the appeal, prompting the petitioner to allege grave abuse of discretion by both the trial court and the appellate court.

The Supreme Court found that the complaint sufficiently stated a cause of action.
The allegations indicated that the petitioner had a primary right ...continue reading