If complaint states NO cause of action, what is the issue?


What is the issue in a motion to dismiss on the ground that the complaint states no cause of action? This is where the hypothetical admission rule comes in.

Admitting the allegations of the complaint, may the court render valid judgment in accordance with its prayer and the law? In other words, assuming for the sake of argument that allegations in the complaint are true, is the complainant entitled, as a matter of law, to the relief prayed for?
Two things should be remembered:

[1] The insufficiency of cause of action must appear on the face of the complaint to sustain a dismissal on that ground.
[2] No extraneous matters may be considered nor facts alleged which would require evidence and therefore, must be raised as defenses and await the trial.