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DIGEST Rule 2 No. 3 Soloil v. Philippine Coconut Authority
DIGEST Rule 2 No. 3 Soloil v. Philippine Coconut Authority
Nature of the Case: Petition for review on certiorari of the decision and resolution of
the Court of Appeals
Legal Doctrine: A cause of action is the act or omission by which a party violates a right
of another. The essential elements of a cause of action are(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 in violation of the right of the
plaintiff or constituting a breach of the obligation of the defendant to the plaintiff for
which the latter may maintain an action for recovery of damages or other appropriate
relief.
Facts:
This is a petition for review of the Decision and Resolution of the Court of
Appeals. The Decision vacated the Decision of the Regional Trial Court (Branch 84) of
Quezon City. The Resolution denied petitioner’s motion for reconsideration.
On 6 December 1995, PCA filed in the Regional Trial Court (Branch 84) of
Quezon City a complaint alleging that Soloil refused to pay the PCA fees. PCA further
claimed that as of 31 December 1994, Soloil’s overdue account had reached
₱403,543.29.
In its answer, Soloil raised the defense that PCA’s demand for the payment of
PCA fees based on domestic sales had no factual basis as Soloil never engaged in the
domestic sale of coconut products.
The case was set for pre-trial. However, for failure of the parties to settle the case
amicably, pre-trial was terminated. Trial on the merits ensued.
PCA presented its lone witness, Trade Control Examiner Victoria Evangelista.
Evangelista testified that she was in charge of monitoring Soloil’s export sales
transactions and that she was the one who prepared Soloil’s Summary of Outstanding
PCA Fee Obligations attached as Annex "A" of the complaint. PCA then presented
itemized schedules of Soloil’s outstanding PCA fee obligations as well as certified
reports of the marine cargo surveyor showing that Soloil made export shipments
without paying the requisite PCA fees.
On the other hand, Soloil presented its sole witness, Assistant Vice-President for
Trading and Administration Fernando Uy. Uy testified that Soloil had no record of any
domestic sale of coconut products. On cross-examination, Uy admitted Soloil purchased
copra in the course of its business of exporting coconut products.
In their respective memoranda, the parties raised the following issues: (1)
whether the complaint stated a cause of action; and (2) if so, whether Soloil was liable to
pay PCA fees in the amount of ₱403,543.29.
In its 29 September 2000 Decision, the RTC ruled PCA failed to prove that the
claimed amount of unpaid PCA fees was from Soloil’s domestic sale of coconut products.
The RTC held that only the amount of ₱509.66 with interest of ₱147.23 was duly proven
to be from Soloil’s domestic sale of coconut products.
PCA appealed to the Court of Appeals insisting that Soloil was liable to pay PCA
fees on its purchases of copra for both domestic and export sale of coconut products.
The appellate court held that PCA fees attached upon purchase of copra by copra
exporters. The Court of Appeals pointed out that there was no distinction whether the
purchase was for domestic or for export sale of coconut products. In its 12 May 2006
Decision, the Court of Appeals granted PCA’s appeal.
Soloil filed a motion for reconsideration, which the Court of Appeals denied for
lack of merit in its 10 October 2006 Resolution.
Issue: Whether or not the complaint, alleging non-payment of PCA fees due on Soloil’s
domestic sale of coconut products, sufficiently stated a cause of action when evidence
adduced during trial consisted of Soloil’s export sale of coconut products.
Ruling:
Petitioner Soloil belabors the fact that the complaint alleged non-payment of PCA
fees on Soloil's domestic sale of coconut products while the attached annexes showing
Soloil's unpaid PCA fees did not indicate whether the amounts due were from domestic
or from export sale of coconut products. Soloil maintains it never had any domestic sale
of coconut products as its sales were all for export. Soloil argues that the complaint
should have been dismissed for lack of cause of action and the RTC should not have
allowed PCA, despite Soloil's vehement objection, to adduce evidence pertaining to
export sales.
Respondent PCA counters that the complaint sufficiently established that PCA
was mandated by law to impose and collect PCA fees for every kilo of copra purchased
by copra exporters such as Soloil. PCA insists that PCA fees attached upon Soloil's
purchase of copra whether such purchase was for domestic or for export sale of coconut
products.
Rule 2 of the Rules of Court defines a cause of action as: Sec. 2. Cause of action,
defined. - A cause of action is the act or omission by which a party violates a right of
another. The essential elements of a cause of action are(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 in violation of the right of the plaintiff or
constituting a breach of the obligation of the defendant to the plaintiff for which the
latter may maintain an action for recovery of damages or other appropriate relief.
This portion of the complaint together with the attached annexes showing
Soloil's unpaid PCA fees sufficiently constituted a cause of action in this case, namely (1)
under P.D. 1854, PCA has a right to collect PCA fees in the amount of three centavos for
every kilo of copra purchased by copra exporters; (2) Soloil, as a copra exporter, is
legally bound to pay PCA fees; and (3) Soloil's non-payment of PCA fees is in violation of
PCA's right to collect the same.
In determining whether a complaint states a cause of action, the trial court can
consider all the pleadings filed, including annexes, motions, and the evidence on record.
The focus is on the sufficiency, not the veracity, of the material allegations. Moreover,
the complaint does not have to establish facts proving the existence of a cause of action
at the outset; this will have to be done at the trial on the merits of the case. The fact that
the complaint specifically mentioned assessed PCA fees due on Soloil's domestic sale of
coconut products did not preclude a cause of action for PCA fees due on Soloil's export
sale of coconut products. PCA sufficiently alleged on paragraph 4 of the complaint that
PCA fees attached upon purchase of copra by copra exporters, such as Soloil, whether
for domestic or for export sale of coconut products.
Presidential Decree No. 1468, otherwise known as the Revised Coconut Industry
Code, granted PCA the power to impose and collect PCA fees to defray its operating
expenses, thus: Sec. 3. Power. - In the implementation of the declared national policy,
the Authority [PCA] shall have the following powers and functions: xxxx k) To impose
and collect, under such rules that it may promulgate, a fee of ten centavos for every one
hundred kilos of desiccated coconut, to be paid by the desiccating factory, coconut oil to
be paid by the oil mills, and copra to be paid by the exporters, which shall be used
exclusively to defray its operating expenses.
Under P.D. 1854, PCA fees automatically attach upon purchase of copra by copra
exporters, such as Soloil in this case. The law does not distinguish whether the purchase
of copra is for domestic or for export sale of coconut products. When the law does not
distinguish, neither should we. However, the law expressly requires that the PCA fees
"shall be paid by said copra exporters" for copra "purchased by copra exporters."
Soloil, as a copra exporter, cannot evade its legal obligation to pay PCA fees on
the lame pretext that it never engaged in domestic sale of coconut products or worse
that the complaint for collection of PCA fees failed to state a cause of action.