Sufficiency of cause of action

In determining the sufficiency of a complaint, the three elements of a cause of action must concur in the allegations therein: (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. (Zuniga-Santos v. Santos-Gran, G. R. No. 197380, 8 October 2014)

The Supreme Court explained in Zuniga-Santos v. Santos-Gran that the basic test in a motion to dismiss on the ground of failure to state a cause of action is whether, assuming the truth of the facts alleged in the complaint, a valid judgment could be rendered in accordance with the relief demanded. As a corollary, only ultimate or essential and not evidentiary facts or legal conclusions are considered for purposes of applying the test. The inquiry is into the sufficiency, not the veracity, of the material allegations. (Zuniga-Santos v. Santos-Gran, G. R. No. 197380, 8 October 2014)