CAUSE OF ACTION UNDER RULE 2 OF THE 1997 RULES OF CIVIL PROCEDURE (PHILIPPINES)
(Elements, Principles, and Key Jurisprudential Points)

1. Definition of a Cause of Action

Under Philippine civil procedure, a cause of action is defined as the act or omission by which a party (usually the defendant) violates the legal right of another (usually the plaintiff). It is that delict or wrongful act or omission which gives rise to an obligation and consequently, the right to bring an action before the courts.

Rule 2, Section 2 of the 1997 Rules of Civil Procedure succinctly states:

A cause of action is the act or omission by which a party violates a right of another.

2. Elements of a Cause of Action

The Supreme Court has consistently enumerated three essential elements that must concur for a valid cause of action to exist:

A Right in favor of the Plaintiff
There must be a right existing in favor of the plaintiff (the claimant). This right may arise from law, contracts, statutes, or any legal source that bestows a right or interest on the plaintiff.
A Correlative Obligation of the Defendant
There must be an obligation or duty on the part of the defendant to respect or not to violate that right of the plaintiff. This means the defendant is legally bound to act or to refrain from acting in a certain way.
An Act or Omission in Violation of the Plaintiff’s Right
The defendant must have failed to comply with, or breached, the duty or obligation such that the plaintiff’s right is infringed or invaded. This wrongful act or omission is what “completes” the cause of action and gives the plaintiff the standing to seek judicial relief.

A complaint that does not allege these three elements—right, obligation, and violation—fails to state a cause of action and is vulnerable to dismissal.

3. Distinction Between ‘Cause of Action’ and ‘Right of Action’

Cause of Action refers to the delict or wrongful act or omission itself and the corresponding duty violated.
Right of Action is the remedial right granted by law to a party to bring suit. A person may have a valid cause of action, but if the right to file suit is lost (e.g., due to prescription), the right of action no longer exists even though the cause of action once existed.

Thus, cause of action pertains to the substantive basis of one’s claim, whereas right of action involves the procedural right to enforce such claim in court.

4. When a Cause of Action Arises

A cause of action arises at the moment the defendant’s act or omission violates the plaintiff’s right. In other words, all three elements must exist simultaneously for a cause of action to “ripen.” No suit may be instituted unless the cause of action has accrued.

Illustrations:

In breach of contract cases, the cause of action arises upon the defendant’s failure to perform or comply with the contractual stipulations.
In tort or quasi-delict cases, the cause of action arises at the time the defendant commits the negligent or wrongful act causing injury to the plaintiff.

5. How to Allege a Cause of Action in the Complaint

Under the Rules, every pleading asserting a claim (e.g., a complaint) must contain a concise statement of the ultimate facts constituting the plaintiff’s cause or causes of action. “Ultimate facts” mean the principal or determinative facts upon which the plaintiff’s right to recover depends, not mere conclusions of law.

Rule 8, Section 1 (1997 Rules of Civil Procedure): Requires that every pleading states the ultimate facts and not evidentiary matters or legal conclusions.

Thus, the complaint must:

State the existence of the plaintiff’s right.
Allege the defendant’s obligation/duty.
Specifically set out the defendant’s wrongful act or omission that violates said right.

If these three are not alleged with sufficient clarity, the complaint risks dismissal for failure to state a cause of action.

6. Test for Sufficiency of Cause of Action (Motion to Dismiss)

A defendant may file a Motion to Dismiss based on the ground that the complaint fails to state a cause of action. In resolving such a motion, the following guidelines apply:

All Averments of Fact Are Deemed True
Courts look only at the allegations in the complaint and hypothetically admit them as true. The court does not consider external or extraneous evidence at this stage.
No Other Facts Beyond the Pleading
The inquiry is confined strictly to the complaint’s four corners. The court merely assesses if, assuming the facts alleged are true, the plaintiff would be entitled to judicial relief.
Liberal Construction
If, by any construction of the facts alleged, the complaint states a cause of action, the motion to dismiss must be denied.

Should the court find that, under no interpretation of the facts alleged can the plaintiff be granted relief, the complaint will be dismissed for failure to state a cause of action.

7. Splitting a Single Cause of Action

Splitting a cause of action occurs when a single cause of action or claim is divided into two or more suits. It is generally prohibited because it leads to multiplicity of suits and potential harassment of the defendant. Rule 2, Section 3 of the 1997 Rules of Civil Procedure provides:

A party may not institute more than one suit for a single cause of action.

Consequences of splitting a cause of action:

If the plaintiff splits a cause of action and brings multiple suits, a final judgment on one suit may be pleaded as res judicata to bar the other suits for the same cause of action.

8. Joinder and Misjoinder of Causes of Action

Joinder of Causes of Action: A party may join multiple causes of action in one complaint against the same defendant if the causes of action arise out of the same transaction or series of transactions, or involve common questions of law or fact.
Misjoinder of Causes of Action: If causes of action are improperly joined, the remedy is severance rather than outright dismissal of the complaint. The misjoined cause(s) of action may be ordered separated or dismissed upon motion or by the court’s initiative.

9. Effect of Lack of Cause of Action

Immediate Dismissal: If the complaint or any pleading on its face shows that the plaintiff does not and cannot have a cause of action (i.e., no amount of amendment can cure it), the court may dismiss the complaint outright.
Dismissal on Motion: Where the complaint fails to state a cause of action, the defendant may file a motion to dismiss.
Amendment: If there is a curable defect (e.g., inadequate factual allegations), the court typically allows the plaintiff to file an amended pleading to properly state a cause of action, consistent with the liberal construction principle of the Rules.

10. Key Philippine Jurisprudence

Asia Brewery, Inc. v. Court of Appeals, 224 SCRA 437 (1993) – Emphasized that in determining the existence of a cause of action, the court looks only at the complaint’s allegations.
Dunlop Slazenger (Phils.), Inc. v. Court of Appeals, 187 SCRA 159 (1990) – Clarified that the complaint must contain a concise statement of the ultimate facts.
Spouses Balangauan v. Court of Appeals, 595 SCRA 162 (2009) – Reiterated that a cause of action exists if the plaintiff’s allegations show a violation of his right by the defendant’s act or omission.
Go Tong Electrical Supply Co. v. Court of Appeals, 281 SCRA 643 (1997) – Distinguished between “failure to state a cause of action” and “lack of cause of action.”

11. Practical Tips and Reminders

Check the Completeness of Your Complaint
Ensure the complaint’s body contains facts showing each of the three elements. Avoid mere legal conclusions, such as “defendant breached the contract,” without factual support.
Anticipate Defenses
While drafting, consider potential arguments from the defendant. If a motion to dismiss is likely on the ground of failure to state a cause of action, ensure that allegations of fact robustly support the conclusion that a right was violated.
Avoid Splitting
If multiple claims arise from the same transaction or series of transactions, join them in a single complaint, if practicable and allowed. Splitting not only wastes time and resources but may also lead to adverse rulings based on res judicata.
Prescriptive Periods
Remember that having a cause of action does not automatically mean you have a right of action forever. Claims may be barred by prescription (expiration of the statutory period) or laches (unreasonable delay). Always consider timeliness.
Amend if Necessary
If the court finds your complaint deficient, it may allow you to amend to cure the defect. Promptly file an amended complaint correcting the omissions or defects in stating the cause of action.

12. Conclusion

Understanding the cause of action is fundamental in civil litigation. The three elements—(1) the plaintiff’s right, (2) the defendant’s obligation, and (3) the defendant’s breach—must be specifically alleged and proven. Failure to articulate these three elements is fatal to any claim. Moreover, procedural rules and relevant jurisprudence emphasize the need to avoid multiplicity of suits by prohibiting splitting and encouraging joinder where appropriate. Ultimately, meticulous drafting of pleadings, clarity in factual allegations, and adherence to the Rules of Court ensure that a valid cause of action is properly presented for judicial determination.