In Clidoro v. Jalmanzar, the Supreme Court clarified that a complaint for revival of judgment should not be dismissed for lack of cause of action if the complaint sufficiently states that the plaintiffs, as prevailing parties in the original action, have a right to seek enforcement of the prior judgment. The Court emphasized that determining the presence of a cause of action is based on the hypothetical admission of the facts alleged in the complaint. This decision underscores the importance of adhering to procedural rules and ensuring that actions for revival of judgment are properly evaluated based on the merits of the allegations presented.

Reviving Justice: Who Can Seek Enforcement of a Dormant Judgment?

This case arose from a complaint filed by Rizalina Clidoro, et al., seeking the revival of a judgment dated November 13, 1995, issued by the Court of Appeals (CA) in CA-G.R. CV No. 19831. This earlier decision had affirmed with modification the RTC Decision dated March 10, 1988, in Civil Case No. T-98 for partition of the estate of the late Mateo Clidoro. The defendants moved to dismiss the complaint, arguing that it was not brought against the real parties-in-interest, substitution of parties was improper, the requirements of Rule 69, Section 3 of the 1997 Rules of Civil Procedure were not met, and the judgment of partition was merely interlocutory. The RTC dismissed the complaint for lack of cause of action, prompting the plaintiffs to appeal to the CA, which reversed the RTC’s decision and remanded the case for further proceedings. This brought the case to the Supreme Court for final resolution. The core legal question revolves around who qualifies as a real party-in-interest in an action for revival of judgment.

The Supreme Court addressed whether the complaint for revival of judgment was correctly dismissed for lack of cause of action because it was allegedly not brought by or against the real parties-in-interest. The Court first clarified a critical procedural point. It emphasized that “lack of cause of action” is not explicitly listed as a ground for dismissal under Rule 16 of the Rules of Court. The Court explained the distinction between “lack of cause of action” and “failure to state a cause of action,” noting that the former is determined during or after trial, while the latter can be grounds for dismissal based on the pleadings alone.

The Court then cited Vitangcol v. New Vista Properties, Inc., elucidating the test for evaluating a motion to dismiss based on failure to state a cause of action:

Lack of cause of action is, however, not a ground for a dismissal of the complaint through a motion to dismiss under Rule 16 of the Rules of Court, for the determination of a lack of cause of action can only be made during and/or after trial. What is dismissible via that mode is failure of the complaint to state a cause of action. Sec. 1(g) of Rule 16 of the Rules of Court provides that a motion may be made on the ground “that the pleading asserting the claim states no cause of action.”

Building on this principle, the Court affirmed that in such motions, the defendant hypothetically admits the truth of the material allegations in the complaint. The ruling should be based solely on the facts alleged in the complaint. The key inquiry, as stated in Manaloto v. Veloso III, is:

When the ground for dismissal is that the complaint states no cause of action, such fact can be determined only from the facts alleged in the complaint and from no other, and the court cannot consider other matters aliunde. The test, therefore, is whether, assuming the allegations of fact in the complaint to be true, a valid judgment could be rendered in accordance with the prayer stated therein.

Applying this test to the case at hand, the Supreme Court noted that the complaint for revival of judgment alleged that the parties involved were also the parties in the original partition action. Hypothetically admitting this allegation, the Court found that the complaint sufficiently stated a cause of action, as the plaintiffs, being the prevailing parties in the partition action, had a right to seek enforcement of the decision.

Furthermore, the Court highlighted that an action for revival of judgment is distinct from the original case. As Saligumba v. Palanog explains, it is a procedural means of securing the execution of a previous judgment that has become dormant. It doesn’t re-open issues of the original case, but is a new and independent action where the cause of action is the decision itself. Thus, the parties in the original case and the revival action may not be exactly the same. What matters is that the parties in the revival action stand to benefit or be injured by the judgment.

The Court examined the list of plaintiffs and defendants in both the original partition case and the action for revival of judgment. It observed that most of the original plaintiffs, in whose favor the partition was adjudged, were also plaintiffs in the revival action. The defendants in the revival action were representatives of the original defendants. Gregoria Clidoro-Palanca, representing defendant Onofre Clidoro, had even been awarded a portion of the estate in the original judgment. This supported the conclusion that the parties in the revival action were indeed the real parties-in-interest.

Drawing from Basbas v. Sayson, the Court noted that even a single co-owner can bring an action for the recovery of co-owned property. Therefore, not all prevailing parties in the partition case needed to be plaintiffs in the revival action. Any party with an interest in the enforcement of the decision could file the complaint. By implication, even if some of the plaintiffs in the revival action were not original parties, their presence did not invalidate the action if at least one real party in interest was present.

In summary, the Supreme Court concluded that the trial court erred in dismissing the complaint for revival of judgment based on a lack of cause of action or failure to state a cause of action. The allegations in the complaint sufficiently indicated the parties’ interest in having the partition decision executed. Any questions regarding whether the respondents were the real parties-in-interest with the right to seek execution should have been resolved through a full trial.

FAQs

What is an action for revival of judgment?	It is a legal action to enforce a judgment that has become dormant because it was not executed within five years of its finality. It essentially renews the judgment’s enforceability for another ten years.
What does it mean to be a “real party-in-interest”?	A real party-in-interest is someone who stands to benefit or be injured by the outcome of the case. They have a direct stake in the subject matter of the litigation.
What is the difference between “lack of cause of action” and “failure to state a cause of action”?	“Lack of cause of action” means that, based on the evidence presented, the plaintiff is not entitled to the relief sought. “Failure to state a cause of action” means that the complaint itself, even if taken as true, does not present a valid legal claim.
Why was the complaint initially dismissed by the RTC?	The RTC dismissed the complaint because it believed that not all parties were the real parties-in-interest, as some of the original parties had died and were represented by others.
How did the Court of Appeals rule on the RTC’s dismissal?	The Court of Appeals reversed the RTC’s decision, holding that the complaint should not have been dismissed on the pleadings alone and that the issue of real parties-in-interest should be determined during trial.
What was the Supreme Court’s final decision in this case?	The Supreme Court affirmed the Court of Appeals’ decision, ruling that the complaint for revival of judgment should be remanded to the trial court for further proceedings.
Can one co-owner file an action for revival of a judgment related to co-owned property?	Yes, even just one of the co-owners can bring an action for revival of judgment to recover co-owned property, as the enforcement of the judgment would benefit all co-owners.
What is the significance of this ruling for future cases?	The ruling clarifies the procedural requirements for actions for revival of judgment and emphasizes the importance of determining the presence of a cause of action based on the allegations in the complaint.

This case serves as a reminder that procedural rules are critical to the fair administration of justice. The Supreme Court’s decision ensures that actions for revival of judgment are properly evaluated, preventing premature dismissals based on technicalities and allowing for a thorough consideration of the merits of the case.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PETRONIO CLIDORO, ET AL. VS. AUGUSTO JALMANZAR, ET AL., G.R. No. 176598, July 09, 2014