Heirs of Dolleton v. Fil-Estate Management, Inc.
,
G.R. No. 170750, April 7,2009
FACTS:
Separate Complaints for Quieting of Title and/or Recovery of Ownership and
Possession with Preliminary Injunction/Restraining Order and Damages were filed
before the RTC by the Petitioners, namely: Heirs of Tomas Dolleton, Heraclio
Orcullo, Remedios San Pedro, et al., Heirs of Bernardo Millama, et al., Heirs of
Agapito Villanueva, et al., Heirs of Hilarion Garcia, et al., Serafina SP Argana, et al.,
and Heirs of Mariano Villanueva, et al., against the respondents Fil-Estate
Management Inc., Spouses Arturo E. Dy and Susan Dy, Megatop Realty
Development, Inc., and the Register of Deeds of Las Piñas.
The eight (8) Complaints were consolidated. The words and allegations thereon
were similar and identical in nature. The Petitioners claimed that they had been
continuous, open and exclusive possession of the disputed parcels of land for
more than ninety (90) years, until they were forcibly ousted by armed men hired
by the respondents.
Respondents filed Motion to Dismiss and Opposition to Application for a
Temporary Restraining Order/Writ of Preliminary Injunction before the Regional
Trial Court on the ground of prescription, laches, lack of cause of action, and res
judicata.
ISSUE:
Whether or not the date of maturity of the instruments is the date of accrual of
cause of action.
RULING:
No. The SC ruled that a cause of action requires, as essential elements, not only a
legal right of the plaintiff and a correlative duty of the defendant but also "an act
or omission of the defendant in violation of said legal right," the cause of action
does not accrue until the party obligated refuses, expressly or impliedly, to comply
with its duty.
Otherwise stated, a cause of action has three elements, to wit, (1) a right in favor
of the plaintiff by whatever means and under whatever law it arises or is created;
(2) an obligation on the part of the named defendant to respect or not to violate
such right; and (3) an act or omission on the part of such defendant violative of
the right of the plaintiff or constituting a breach of the obligation of the defendant
to the plaintiff.
It bears stressing that it is only when the last element occurs that a cause of action
arises. Accordingly, a cause of action on a written contract accrues only when an
actual breach or violation thereof occurs. Applying the foregoing principle to the
instant case, we rule that private respondent’s cause of action accrued only on
July 20, 1995, when its demand for payment of the Home Notes was refused by
petitioner. It was only at that time, and not before that, when the written contract
was breached and private respondent could properly file an action in court.
