Sufficiency of civil complaint

A complaint states a cause of action if it sufficiently avers the existence of the three (3) essential
elements of a cause of action, namely: (a) a right in favor of the plaintiff by whatever means and
under whatever law it arises or is created; (b) an obligation on the part of the named defendant to
respect or not to violate such right; and (c) an act or omission on the part of the named defendant
violative of the right of the plaintiff or constituting a breach of the obligation of defendant to the
plaintiff for which the latter may maintain an action for recovery of damages. If the allegations of the
complaint do not state the concurrence of these elements, the complaint becomes vulnerable to a
motion to dismiss on the ground of failure to state a cause of action.
It is well to point out that the plaintiff’s cause of action should not merely be "stated" but, importantly,
the statement thereof should be "sufficient." This is why the elementary test in a motion to dismiss on
such ground is whether or not the complaint alleges facts which if true would justify the relief
demanded. As a corollary, it has been held that only ultimate facts and not legal conclusions or
evidentiary facts are considered for purposes of applying the test. This is consistent with Section 1,
Rule 8 of the Rules of Court which states that the complaint need only allege the ultimate facts or the
essential facts constituting the plaintiff’s cause of action. A fact is essential if they cannot be stricken
out without leaving the statement of the cause of action inadequate. Since the inquiry is into the
sufficiency, not the veracity, of the material allegations, it follows that the analysis should be confined
to the four corners of the complaint, and no other. (ELIZA ZUNIGA-SANTOS vs. MARIA DIVINA
GRACIA SANTOS-GRAN, ET AL., G.R. No. 197380, 8 October 2014)
Sufficiency of answer
We find defendant's appeal to be frivolous. No error was committed by the Court below in ruling that
defendant-appellant's "specific denials" are in law general denials amounting to admissions of the
material allegations of the complaint and in rendering judgment on the pleadings, in accordance with
the settled doctrine in this jurisdiction based on the provisions of the Rules (updated):
Rule 8
Section 10. Specific denial. — A defendant must specify each material allegation of fact the truth of
which he does not admit and, whenever practicable, shall set forth the substance of the matters
upon which he relies to support his denial. Where a defendant desires to deny only a part of an
averment, he shall specify so much of it as is true and material and shall deny only the remainder.
Where a defendant is without knowledge or information sufficient to form a belief as to the truth of a
material averment made to the complaint, he shall so state, and this shall have the effect of a denial.
Section 11. Allegations not specifically denied deemed admitted. — Material averments in the
complaint, other than those as to the amount of unliquidated damages, shall be deemed admitted
when not specifically denied. Allegations of usury in a complaint to recover usurious interest are
deemed admitted if not denied under oath.
Rule 34
Section 1. Judgment on the pleadings. — Where an answer fails to tender an issue, or otherwise
admits the material allegations of the adverse party's pleading, the court may; on motion of that
party, direct judgment on such pleading. However, in actions for declaration of nullity or annulment of
marriage or for legal separation, the material facts alleged in the complaint shall always be proved.
Rule 35
Section 1. Summary judgment for claimant. — A party seeking to recover upon a claim,
counterclaim, or cross-claim or to obtain a declaratory relief may, at any time after the pleading in
answer thereto has been served, move with supporting affidavits, depositions or admissions for a
summary judgment in his favor upon all or any part thereof.
Section 3. Motion and proceedings thereon. — The motion shall be served at least ten (10) days
before the time specified for the hearing. The adverse party may serve opposing affidavits,
depositions, or admissions at least three (3) days before the hearing. After the hearing, the judgment
sought shall be rendered forthwith if the pleadings, supporting affidavits, depositions, and
admissions on file, show that, except as to the amount of damages, there is no genuine issue as to
any material fact and that the moving party is entitled to a judgment as a matter of law.
This doctrine was first established by the Court twenty-six years ago in the case of El Hogar Filipino
vs. Santos Investments, Inc., where this Court, in applying the provisions on specific denials required
of the defendant in Rule 9, section 7 of the then new Rules of Court, now found in Rule 8, section 10
of the Revised Rules of Court above-quoted, held that "Defendant's answer wherein it merely 'denies
generally and specifically each and every allegation contained in each and every paragraph of the
complaint,' is but a general denial. It is not a specific denial under section 7 of Rule 9, because it
does not deal specifically with each material allegation of fact, nor does it set forth the substance of
the matters upon which the defendant relies to support his denial. It does not serve the purpose of
requiring the defendant to make a specific denial, which is to compel him to specify the matters
which he intends to disprove and disclose the matters upon which he relies to support his denial,
thereby limiting the issues and avoiding unnecessary delays and surprises. Under the old procedure
the plaintiff was compelled by defendant's mere general denial to prove facts alleged in the
complaint which the defendant did not even attempt to dispute. The new procedure does away with
that unnecessary burden. (Moran on the Rules of Court, volume 1, page 93.)" This doctrine has
since been applied uniformly in a long line of cases.
Time and again, this Court has stressed that "An unexplained denial of information and belief of a
matter of records, the means of information concerning which are within the control of the pleader, or
are readily accessible to him, is evasive and is insufficient to constitute an effective denial. ..." and
that "the form of denial ... adopted by the appellants, although allowed by the Rules of Court
(referring to lack of sufficient knowledge or information) must be availed of with sincerity and in good
faith, — certainly neither for the purpose of confusing the adverse party as to what allegations of the
complaint are really put in issue nor for the purpose of delay."
Defendant-appellant has no cause to complain of the judgment appealed from. Its claim that it
tendered an issue with its "affirmative defense" of "having no obligation to pay to the plaintiff the
amount or sum of money claimed in the complaint" was correctly held by the Court below to be a
mere conclusion not premised on an allegation of material facts. Its "specific denial" of the material
allegations of the complaint as to its purchase of the office equipment from plaintiff under the
purchase order annexed to the complaint and refusal to pay the unpaid balance of P900.00 due
thereon, without setting forth the substance of the matters relied upon to support its general denial,
when such matters were plainly within its knowledge and it could not logically pretend ignorance as
to the same, therefore, failed to properly tender an issue. Furthermore, its failure to deny under oath
the authenticity of the purchase order annexed to the complaint, as required by Rule 8, section 8 of
the Revised Rules of Court was properly deemed an admission of the genuineness and due
execution thereof. There is nothing in the record to justify defendant's pretense in its brief that the
said purchase order "merely shows the defendant's offer to buy the (articles) from the plaintiff," as
against the material averments of the complaint, deemed admitted by it, that the articles were
delivered to it, and that it paid an amount of P990.00 on account of the purchase price, leaving an
unpaid balance of P900.00, which it had failed and refused to pay all this time. Verily, as this Court
pointed out in the Syquia vs. Marsman case, supra, the Court will not sanction a strategy of evasion
systematically adopted by a defendant of trapping and confusing the plaintiff as to what facts the
plaintiff has to prove or what issues must be met, for "it is violative of fair disclosure of facts required
by the Rules." (J. P. JUAN & SONS, INC. vs. LIANGA INDUSTRIES, INC., G.R. No. L-25137, 28
July 1969)

Sufficiency of criminal complaint

In all criminal prosecutions, the accused is entitled to be informed of the nature and cause of the
accusation against him. A complaint is sufficient if it states the name of the accused; the designation
of the offense given by the statute; the acts or omissions complained of as constituting the offense;
the name of the offended party; the approximate date of the commission of the offense; and the
place where the offense was committed.
The complaint or information shall state the designation of the offense given by the statute, aver the
acts or omissions constituting the offense, and specify its qualifying and aggravating circumstances.
If there is no designation of the offense, reference shall be made to the section or subsection of the
statute punishing it. The acts or omissions complained of as constituting the offense and the
qualifying and aggravating circumstances must be stated in ordinary and concise language and not
necessarily in the language used in the statute but in terms sufficient to enable a person of common
understanding to know what offense is being charged as well as its qualifying and aggravating
circumstances and for the court to pronounce judgment. (ISIDRO OLIVAREZ vs. COURT OF
APPEALS, ET AL., G.R. No. 163866, 29 July 2005)

THE REAL NATURE OF THE OFFENSE IS DETERMINED BY FACTS ALLEGED IN THE

INFORMATION, NOT BY THE DESIGNATION
The designation in the information of the specific statute violated is imperative to avoid surprise on
the accused and to afford him the opportunity to prepare his defense accordingly. However, the
failure to designate the offense by statute, or to mention the specific provision penalizing the act, or
an erroneous specification of the law violated does not vitiate the information if the facts alleged
clearly recite the facts constituting the crime charged. What controls is not the title of the information
or the designation of the offense but the actual facts recited in the information. In other words, it is
the recital of facts of the commission of the offense, not the nomenclature of the offense, that
determines the crime being charged in the information. (MICHAEL JOHN Z. MALTO vs. PEOPLE
OF THE PHILIPPINES, G.R. No. 164733, 21 September 2007)