In the case of Victorina (Victoria) Alice Lim Lazaro v. Brewmaster International, Inc., the Supreme Court reiterated the importance of the allegations in the complaint as the primary basis for judgment, especially in cases governed by the Revised Rule on Summary Procedure. The Court ruled that when a defendant fails to appear during the preliminary conference, the judgment should be based on the facts alleged in the complaint. This means the court should determine if the complaint sufficiently states a cause of action that warrants the relief sought by the plaintiff. This ruling underscores the need for plaintiffs to ensure their complaints are clearly and completely drafted, as the court may rely solely on these allegations to render a decision if the defendant defaults.

When a No-Show Speaks Volumes: Default Judgment and the Duty to Pleadings

Brewmaster International, Inc. filed a complaint against Victorina Lazaro and her husband Prescillo for a sum of money, representing unpaid beer and other products purchased on credit. The complaint alleged that the couple owed Php 138,502.92, and despite repeated demands, failed to settle the obligation. The Metropolitan Trial Court (MeTC) initially dismissed the case, pointing out that the sales invoices indicated the goods were sold to “TOTAL” and received by a certain Daniel Limuco, not the Lazaros themselves. However, the Court of Appeals (CA) reversed this decision, emphasizing that because the defendants failed to appear during the preliminary conference, judgment should be based on the facts alleged in the complaint, as dictated by the Revised Rule on Summary Procedure. This case highlights the critical importance of the pleadings in summary procedure, especially when a party fails to participate in the proceedings.

The Supreme Court upheld the CA’s decision, reiterating that the allegations in the complaint must sufficiently state a cause of action for the plaintiff to be entitled to relief. A cause of action exists when there is a right in favor of the plaintiff, a corresponding obligation on the part of the defendant to respect such right, and an act or omission by the defendant in violation of that right. The Court emphasized that the basic requirement is that a complaint must make a plain, concise, and direct statement of the ultimate facts on which the plaintiff relies for his claim. These ultimate facts are the essential facts constituting the plaintiff’s cause of action, not the details of probative matter or particulars of evidence.

The test for determining the sufficiency of the facts alleged in a complaint is whether, admitting the facts alleged, the court could render a valid judgment upon the same in accordance with the prayer of the petition or complaint. Furthermore, all documents attached to the complaint may be considered to determine whether it states a cause of action, especially when referred to in the complaint. However, the Court was careful to clarify that the inquiry is into the sufficiency, not the veracity, of the material allegations in the complaint. Thus, the annexed documents should only be considered in the context of ascertaining the sufficiency of the allegations in the complaint.

In this case, the Supreme Court found that the complaint sufficiently stated a cause of action against Victorina Lazaro. The complaint alleged that Victorina and her husband obtained beer and other products on credit from Brewmaster and that they refused to pay the amount despite demand. These allegations, if proven, would establish a valid claim for a sum of money. The Court also clarified that the sales invoices, which named Total as the purchaser, were not the bases of the action but were attached to provide details on the alleged transactions. These sales invoices were considered evidentiary in nature and not essential to be stated or cited in the complaint. Thus, the court looked into the ‘TOTAL’ being operated by Victorina and her husband making them liable for the products purchased on credit from Brewmaster, as it can be recalled in the case.

Moreover, the Supreme Court stated that even if the sales invoices were considered, they would not necessarily negate Victorina’s liability. An invoice is merely a detailed statement of the nature, quantity, and cost of the goods sold and is not considered a bill of sale. The Court cited Peña v. Court of Appeals, where it held that sales invoices are not conclusive of the extent and the nature of the involvement of the parties in the sales of the products under the said sales invoices which are not absolutely binding. They may be explained and put to silence by all the facts and circumstances characterizing the true import of the dealings to which they refer. The facts contained in the said sales invoices may be contradicted by oral testimony.

The ruling in Lazaro v. Brewmaster International serves as a reminder to parties involved in litigation, particularly in cases governed by the Revised Rule on Summary Procedure, of the importance of actively participating in the proceedings. The failure to appear during the preliminary conference can have significant consequences, as the court may base its judgment solely on the allegations in the complaint. Moreover, the case underscores the need for plaintiffs to ensure that their complaints clearly and completely state a cause of action, as the sufficiency of these pleadings is critical to obtaining relief. This principle aligns with the broader legal framework, as illustrated in Section 6 of the Revised Rule on Summary Procedure:

Sec. 6. Effect of failure to answer. – Should the defendant fail to answer the complaint within the period above provided, the court, motu proprio, or on motion of the plaintiff, shall render judgment as may be warranted by the facts alleged in the complaint and limited to what is prayed for therein: Provided, however, That the court may in its discretion reduce the amount of damages and attorney’s fees claimed for being excessive or otherwise unconscionable. This is without prejudice to the applicability of Section 4, Rule 18 of the Rules of Court, if there are two or more defendants.

This provision clearly indicates that the court’s judgment is directly linked to the facts alleged in the complaint, reinforcing the significance of well-drafted and comprehensive pleadings. Building on this principle, the court’s analysis of the sales invoices further clarifies the distinction between evidentiary documents and the essential elements of a cause of action. While documentary evidence can support the claims made in the complaint, the cause of action itself must be sufficiently stated within the pleadings.

In conclusion, the Supreme Court’s decision in Lazaro v. Brewmaster International affirms the critical role of pleadings in summary procedure and reinforces the duty of parties to actively participate in litigation. The case serves as a valuable lesson for both plaintiffs and defendants, emphasizing the importance of clear, complete, and well-supported pleadings in achieving a favorable outcome in court.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals erred in reversing the Regional Trial Court’s decision and granting relief to Brewmaster International based on Section 6 of the Revised Rules of Summary Procedure. This hinged on whether the complaint stated a sufficient cause of action against Victorina Lazaro.
What is the Revised Rule on Summary Procedure?	The Revised Rule on Summary Procedure is a set of rules designed to expedite the resolution of certain civil cases, primarily those involving small claims. It streamlines the process and reduces the time required for litigation.
What constitutes a cause of action?	A cause of action consists of three elements: a right in favor of the plaintiff, a corresponding obligation on the part of the defendant to respect such right, and an act or omission by the defendant in violation of that right. All three elements must be present for a cause of action to exist.
What are ultimate facts in a complaint?	Ultimate facts are the essential and substantial facts that directly form the basis of the plaintiff’s primary right and the defendant’s wrongful acts or omissions. These are the principal, determinative, and constitutive facts upon which the cause of action rests.
How are sales invoices treated as evidence in this case?	Sales invoices were treated as evidentiary documents that provide details on the alleged transactions but are not the basis of the action for sum of money. They are considered not conclusive and may be contradicted by other evidence.
What happens if a defendant fails to appear during the preliminary conference in a summary procedure case?	If a sole defendant fails to appear, the plaintiff is entitled to judgment in accordance with Section 6 of the Revised Rules on Summary Procedure. The judgment will be based on the facts alleged in the complaint, limited to what is prayed for therein.
Can documents attached to the complaint be considered in determining whether a cause of action exists?	Yes, all documents attached to the complaint may be considered to determine whether it states a cause of action, especially when referred to in the complaint. However, the inquiry is into the sufficiency, not the veracity, of the material allegations in the complaint.
What was the outcome of the case?	The Supreme Court affirmed the Court of Appeals’ decision, ordering Victorina Lazaro and her husband to pay Brewmaster International the amount of P138,502.92, plus interest, and the costs of suit.

The Supreme Court’s decision in Lazaro v. Brewmaster International reinforces the importance of adhering to procedural rules and ensuring that pleadings are clear, complete, and well-supported. This case serves as a valuable precedent for future litigation involving similar issues, providing guidance on the interpretation and application of the Revised Rule on Summary Procedure.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Victorina (Victoria) Alice Lim Lazaro, vs. Brewmaster International, Inc., G.R. No. 182779, August 23, 2010