Case Summary (G.R. No. 198680)
Facts
Magdaleno Ypon died intestate and without legitimate descendants on June 28, 1968, leaving the subject parcels. In 2010, petitioners and other collateral relatives filed a complaint for Cancellation of Title and Reconveyance with Damages (Civil Case No. T-2246, RTC Toledo City, Branch 59), alleging that Gaudioso, though only a collateral heir, wrongfully executed an Affidavit of Self-Adjudication, caused cancellation of the original titles, and had the parcels transferred to himself. Gaudioso answered, asserting that he was Magdaleno’s legitimate son and compulsory heir, supporting his claim with a birth certificate, academic letters, and a passport. He further defended on grounds that petitioners lacked cause of action and were not judicially declared heirs.
Procedural History
On July 27, 2011, the RTC dismissed Civil Case No. T-2246 for failure to state a cause of action, holding that heirship could not be resolved in the cancellation suit and that Gaudioso had sufficiently established his filial relationship. A motion for reconsideration was denied on August 31, 2011, due to counsel’s failure to comply with Mandatory Continuing Legal Education requirements. Petitioners then filed a petition for review on certiorari under Rule 45 before the Supreme Court.
Issue
Whether the RTC properly dismissed the complaint for lack of cause of action on the ground that the determination of lawful heirs must be made in a special proceeding rather than in an ordinary action for cancellation of title and reconveyance.
Applicable Law
• Constitution: 1987 Philippine Constitution (decision rendered in 2013).
• Rules of Court: Rule 45 (Certiorari), Rule 90, Section 1 (special proceedings for determination of heirs), Section 2, Rule 2 (cause of action defined), Section 3, Rule 1 (distinction between civil action and special proceeding).
• Jurisprudence: Heirs of Teofilo Gabatan v. CA; Litam v. Rivera; Solivio v. Court of Appeals; Milagros Joaquino v. Reyes; Agapay v. Palang; Republic v. Mangotara; Portugal v. Portugal-Beltran.
Supreme Court Ruling
- Cause of Action. The Court reaffirmed that a complaint states a cause of action when its allegations, taken as true on their face, entitle the plaintiff to the relief prayed for, irrespective of any defenses. Petitioners’ complaint alleged heirship and sought to nullify Gaudioso’s self-adjudication and cancel the titles issued in his favor.
- Special Proceeding Requirement. The Court held that matters involving the determination of lawful heirs constitute status-establishing claims reserved for special proceedings under Rule 90, Section 1, and cannot be adjudicated in ordinary civi
Case Syllabus (G.R. No. 198680)
Procedural History
- Petitioners sought a direct recourse to the Supreme Court by petition for review on certiorari under Rule 45, challenging the dismissal of Civil Case No. T-2246 by the Regional Trial Court (RTC) of Toledo City, Branch 59.
- The RTC issued two key orders:
• July 27, 2011 Order dismissing the complaint for lack of cause of action.
• August 31, 2011 Order denying petitioners’ motion for reconsideration due to a defect in counsel’s MCLE compliance certificate.
Facts
- July 29, 2010: Petitioners, collateral relatives of the deceased, filed a Complaint for Cancellation of Title and Reconveyance with Damages (Civil Case No. T-2246) against Gaudioso P. Ricaforte a.k.a. Gaudioso E. Ypon.
- Allegations in the complaint:
• Magdaleno Ypon died intestate and without issue on June 28, 1968, leaving several parcels covered by TCT Nos. T-44 and T-77-A.
• Gaudioso executed an Affidavit of Self-Adjudication as sole heir, caused cancellation of the original TCTs, and transferred titles to himself under TCT Nos. T-2637 and T-2638.
• Petitioners, as collateral heirs, claimed prejudice from the cancellation and sought nullification of the Affidavit and cancellation of the new titles. - Gaudioso’s Answer:
• Asserted he is the lawful son and compulsory heir of Mag